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Respondent denied petitioner’s claim for a deduction in taxable
year 1988 for the remaining amount of the loss associated with
the sale of the loan portfolio (i.e., $85.6 million).
Organizational Structure and History
On October 31, 1988, and at all prior times relevant hereto,
Standard Chartered Holdings, Inc. (Standard Chartered) was the
sole shareholder of Union Bancorp, which in turn was the sole
shareholder of Union Bank, a U.S. corporation. Standard
Chartered Overseas Holdings, Ltd. (SCOH), a United Kingdom
corporation, owned all of the stock in Standard Chartered.
Standard Chartered Bank (Standard Chartered-U.K.), a United
Kingdom corporation, owned all of the stock in SCOH. Therefore,
Standard Chartered-U.K. was the indirect parent of Union Bank.
On October 31, 1988, SCOH sold all its stock in Standard
Chartered to California First Bank, an unrelated party. On
November 1, 1988, Standard Chartered and its subsidiaries, Union
Bancorp and Union Bank, were liquidated into California First
Bank. California First Bank then changed its name to Union Bank.
On April 1, 1996, BanCal Tri-State Corp., a Delaware
corporation and parent of The Bank of California, merged into
Union Bank, with Union Bank surviving. Union Bank transferred
all the assets of its banking business to The Bank of California,
and Union Bank then changed its name to petitioner's present
name, UnionBanCal Corp.
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