- 6 - issued debt in the Eurobond market, generally guaranteed by the U.S. parent corporation, and lent the proceeds to the U.S. parent or its affiliates. Depending on the facts in a particular case, the U.S. parent’s payment of interest on its indebtedness to the Netherlands Antilles finance subsidiary might be exempt from withholding tax by reason of the application of the U.S.- Netherlands Income Tax Convention, as extended by protocol to the Netherlands Antilles. City’s Finance Subsidiary In June 1974, City organized a subsidiary in the Netherlands Antilles named City Investing Finance N.V. (Finance) to facilitate access to the Eurobond market. At some point, 20 shares of Finance’s common stock at $1,000 par value were issued to City. City made a payment of $1,000 for 1 share of Finance’s stock in May 1978; the remaining $19,000 due from City was treated as a “subscription receivable” on Finance’s financial statements. In 1977 and 1979, City undertook to raise approximately $30 million and $50 million, respectively, from sources outside the United States by having Finance issue notes in these amounts in the Eurobond market. The payment of principal and interest on these notes was unconditionally guaranteed by City. Finance immediately transferred the proceeds from the notes to City, in exchange for City’s promissory notes. Before issuance ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011