- 20 - (c) Irrespective of whether you understand the entity receiving the funds to be Deitsch Plastic Company or Deitsch Plastic Partners, please explain your understanding of the work performed to earn the funds received from FIL. * * * * * * * (e) Explain your understanding of the work performed by the shareholders to earn the special commissions. Please provide any documentation supporting this understanding. The October 14, 1999, response from Israel’s Ministry of Finance reads: These are the answers from the Assessing Office: (a) Flocktex did not pay dividends to shareholders in the years 1992-1993, but instead paid a special commission. Files or reports for the 1991-tax year are unobtainable at such short notice. We requested this information and would be able to complete our answer upon its arrival. (b) The Assessing Officer does not distinguish between the two separate companies. (c) The taxpayers contended that the payments were for services rendered in form of management and consulting services. The Israeli company reported the payments as such. There was no question that management services have actually been given. Examination of the work performed to earn this income was not pursued any further. (e) As in (c) above.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011