To be clear, the FO wr= ites up the books of Phaidon Global LLC. Any money borrowed from BFP LP (on=From: Richard Kahn
Case File
efta-efta01197619DOJ Data Set 9OtherFrom: Peter Goodwin
Date
Unknown
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DOJ Data Set 9
Reference
efta-efta01197619
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1
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From: Peter Goodwin
To: Richard Joslin
CC: John Murphy
Subject: Foreign Corps Tax
Date: Mon, 06 Oct 2014 16:13:54 +0000
Attachments: FOREIGNCOMPLPWC2013-LOWER ENTITIES.xlsx;
FOREIGN COMPL PWC 2013- TOP END ENTITIES.xlsx;
FOREIGN COMPL PWC JAPAN 2012.xlsx
Hi Richard,
Please find attached the worksheets for the top & lower entities for Dec 2013 and also Japan for Dec 2012.
The JMWT companies are as at June 2014 but there would have been no movement from Dec 2013 onwards. I have
assumed that the intra-group loan between LLP & Midco will have been repaid along with any interest via the inter-
company accounts. Goodwill is not an issue as these are the company accounts, not consolidated.
You will need to enter the closing exchange rate for the balance sheet and the average for the P&L in cell Dl of the
respective sheets
Kind Regards
Pete
EFTA01197619
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