person

By services, 28 November, 2015

The taxpayer (a Canadian subsidiary of a U.S. corporation ("Gillette Boston")) contributed a 9.9% interest in a French partnership that was 90% owned by Gillette Boston, to a French subsidiary ("Oral B France") in consideration for shares. The partnership repurchased the partnership interest held by Oral B France in exchange for a note, Oral B France repurchased the shares in its capital held by the taxpayer in exchange for an assignment of the note, and the note was converted into a loan with the loan not being repaid until almost five years later.