InterTAN, Inc. - Page 18

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          petitioner’s 1993 Schedule C.                                               
               In the fall of 1996, respondent began an examination of                
          petitioner’s taxable years ended June 30, 1990, 1991, 1992, and             
          1993.  On October 8, 1996, petitioner mailed to respondent a                
          letter on petitioner’s letterhead, entitled “STATEMENT FURNISHED            
          UNDER REVENUE PROCEDURE 94-69", which respondent received on                
          October 11, 1996 (October 11, 1996 disclosure letter).  Price               
          Waterhouse had drafted that letter.  The October 11, 1996 disclo-           
          sure letter stated in pertinent part:                                       
               As previously disclosed to the Internal Revenue Service                
               (IRS) in July 1995, and on September 24, 1996,                         
               InterTAN, Inc. [petitioner] is facing under Internal                   
               Revenue Code Section 905(c) a potential redetermination                
               of the foreign tax credits claimed on its U.S. income                  
               tax returns for the years ended June 30, 1990 through                  
               June 30, 1993.  The redetermination could arise from a                 
               potential deficit in the post-1986 pool of foreign                     
               taxes for InterTAN Canada Ltd. (InterTAN Canada) [ITC].                
               In this eventuality, InterTAN, Inc.’s foreign tax                      
               credits would be required to be redetermined pursuant                  
               to Treasury Regulation Section 1.905-3T(d)(4)(iv) with                 
               notification made by InterTAN Inc. pursuant to Treasury                
               Regulation Section 1.905-4T(b).                                        
               The dividends paid by InterTAN Canada from the 1988                    
               through 1992 tax years are as follows:                                 
                                              Deemed-paid                             
               Tax      Type of                  Foreign Tax   Grossed-up             
               Year     Dividend  Amount         Credit        Dividend               
               1988   Preferred   $23,910,500    $15,720,834   $39,631,334            
                         Stock                                                        
                      Redemption                                                      
               1989   Preferred   13,570,739     8,745,782     22,316,521             
                         Stock                                                        
                      Redemption                                                      
               1992   Preferred   20,000,000     18,236,696    38,236,696             
                         Stock                                                        
                      Redemption                                                      






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