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30, 1993 letter, Royal Bank deposited that check into peti-
tioner’s Royal Bank account.
On July 2, 1993, Royal Bank received a letter (July 2, 1993
letter) from Mr. Neumann. The July 2, 1993 letter stated in
pertinent part:
Would you please accomplish the following on behalf of
InterTAN Inc. [petitioner] and its wholly owned subsid-
iary InterTAN Canada Ltd. [ITC]:
1. The enclosed cheque in the amount of
US$20,000,000.00 drawn on InterTAN Inc. account
number 302-0402-4 [petitioner’s Royal Bank ac-
count] is to be deposited in InterTAN Canada Ltd.
account number 302-8529-6 as a loan from InterTAN
Inc. to InterTAN Canada Ltd.
2. Withdraw the sum of US$20,000,000.00 from the
account of InterTAN Canada Ltd. account number
302-8529-6 to satisfy an overdraft owing to Royal
Bank by InterTAN Canada Ltd.
On July 2, 1993, pursuant to the July 2, 1993 letter, the
following actions occurred:
4. The check enclosed with the July 2, 1993 letter that was
drawn upon petitioner’s Royal Bank account at Royal Bank and
payable to ITC in the amount of $20 million was presented to
Royal Bank. Pursuant to the July 2, 1993 letter, Royal Bank
deposited that check into ITC’s Royal Bank account.
5. Royal Bank debited ITC’s Royal Bank account in the
amount of $20 million, which ITC had received from petitioner on
July 2, 1993, as described above as action 4, in order to satisfy
ITC’s overdraft.
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