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<blockquote data-quote="InsideUPS" data-source="post: 1101499" data-attributes="member: 31414"><p>You sure seem a little "sensitive" on this topic Hoaxster.... <strong><span style="color: #008000">The Internet is full of information about the controversy surrounding OPL...."sham" sure comes up a lot and that is NOT my word. OPL must have been near and dear to your Atlanta heart.</span></strong></p><p><strong><span style="color: #008000"></span></strong></p><p><span style="font-size: 12px">The IRS attacked the foregoing on several grounds but basically argued that the arrangement was essentially a <span style="color: #ff0000">"<u>sham</u>"</span> with no economic sub-</span></p><p><span style="font-size: 12px">stance and no business purpose other than tax savings and simply a diver- sion (i.e. assignment) of income in fact earned by UPS to another com- monly controlled offshore entity.</span></p><p><span style="font-size: 12px">The Tax Court essentially agreed with the IRS and<span style="color: #ff0000"> treated the whole arrangement as a <u>sham</u></span>, largely based on their perception that UPS continued to do most of the same business functions surrounding the EVC activity after the restructuring that it had done prior to the restructuring.</span></p><p><span style="font-size: 12px"></span></p><p><span style="font-size: 12px"></span></p><p>Just one more link.... <a href="http://www.andersonkill.com/webpdfext/PE-200110CorpCnsl.pdf" target="_blank">http://www.andersonkill.com/webpdfext/PE-200110CorpCnsl.pdf</a></p></blockquote><p></p>
[QUOTE="InsideUPS, post: 1101499, member: 31414"] You sure seem a little "sensitive" on this topic Hoaxster.... [B][COLOR=#008000]The Internet is full of information about the controversy surrounding OPL...."sham" sure comes up a lot and that is NOT my word. OPL must have been near and dear to your Atlanta heart. [/COLOR][/B] [SIZE=3]The IRS attacked the foregoing on several grounds but basically argued that the arrangement was essentially a [COLOR=#ff0000]"[U]sham[/U]"[/COLOR] with no economic sub-[/SIZE] [SIZE=3][/SIZE][SIZE=3]stance and no business purpose other than tax savings and simply a diver- sion (i.e. assignment) of income in fact earned by UPS to another com- monly controlled offshore entity.[/SIZE] [SIZE=3][/SIZE][SIZE=3]The Tax Court essentially agreed with the IRS and[COLOR=#ff0000] treated the whole arrangement as a [U]sham[/U][/COLOR], largely based on their perception that UPS continued to do most of the same business functions surrounding the EVC activity after the restructuring that it had done prior to the restructuring. [/SIZE] Just one more link.... [url]http://www.andersonkill.com/webpdfext/PE-200110CorpCnsl.pdf[/url] [/QUOTE]
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