118 T.C. No. 13 UNITED STATES TAX COURT ELECTRONIC ARTS, INC. AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent ELECTRONIC ARTS PUERTO RICO, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 2433-99, 2434-99. Filed March 22, 2002. Before the years in issue, petitioner parent (EA) had relied on unrelated video games manufacturers in Taiwan and Japan to manufacture the video games that EA sold. EA created a subsidiary (EAPR) to move the video game manufacturing operations to Puerto Rico. EAPR entered into agreements with an unrelated company (PPI), which was located in Puerto Rico. PPI manufactured ignition modules and related products for small engines. PPI did not own equipment, raw materials, or components to manufacture video games. Under the EAPR-PPI agreements, EAPR leased space in PPI’s factory, leased employees from PPI, bought capital equipment which was installed in the leased space, bought components and raw materials, and provided the foregoing to PPI in order to manufacture video games. PPI was paid for its services. EAPR sold the resulting video games to EA. The video games inPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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