- 19 -
years 1994-1996, but instead paid a special commission.” The
letter continued, specifically in response to inquiries about the
payments to DPP, with the following:
The payments described were reported and deducted,
following the tax commisioners’ [sic] inquiry, the
company’s representations and ultimately an agreement
reached by the two parties, as consulting fees. There
has been no change in this position in the company’s
reports. The deduction was not removed and the taxable
income remained as before. The agreement included,
however, additional taxation of these payments prior to
the Tax Commissioners [sic] permit to transfer these
funds abroad. Therefor, [sic] it seems that in terms
of Israeli taxation, there could be no adjustments made
at this point and there would be no effect on Israeli
taxation as a result of the adjustments made in the
U.S.
Then, in answer to questions regarding the special commissions,
the taxing authorities provided that “These payments were
reported and deducted as described above.”
After receiving this communication, the IRS sent an
additional letter requesting from the Israeli administration the
further specific assistance set forth below:
(a) Confirm that, similar to 1994-1996, for 1991-1993,
FIL did not pay any dividends to shareholders.
(b) Explain which entity you mean by the name “Deitsch
Plastic”. Does it mean Deitsch Plastic Company or
Deitsch Plastic Partners? Does it recognize that
these are two separate companies? Provide any
information submitted by FIL and/or its
accountants explaining its relationship to Deitsch
Plastic Company and Deitsch Plastic Partners.
Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NextLast modified: May 25, 2011