Examples of NN Ireland in a sentence
The agreement was signed by NNL, NNI, NNUK, NNSA and NN Ireland at various dates and made effective January 1, 2001.
An R&D CSA between NNL and NN Ireland was also in place at this time, and similarly appears to have contained substantially the same terms as the 1992 NNL-NNI R&D CSA.TR31309 (1995 NNL-NNUK R&D CSA); TR46945 (2000 NNL-NNSA R&DCSA); TR11055 (Horst Frisch Report) at 10, 38.
NNSA and NN Ireland totaled $9.2 billion, with NNI spending at least $6.5 billion of that total on R&D conducted at its facilities.
For example, between approximately 2000 and 2003, NNUK was a net borrower of over $1 billion from NN Ireland, Nortel Matra Cellular (predecessor to NNSA), NN Australia, NN Singapore, NN Europe Sales, H.O.C. (a Hungarian financing subsidiary) and NNI.
TR00055 (Ryan Rebuttal) at 2-3, 15-17, Ex. D; Trial Tr. 4494:19-4495:9, 4578:5-23 (Ryan); see, e.g., TR47129 (cost sharing worksheet, including data for NNL, NNI, NN Ireland, and, for 1995-2000, NNUK ), Tab “Post Transfer Pricing Dec 31st”, Row 193 (listing “R&D Expense,” which equates to Direct R&D Spend), Row 482, (listing the “Inc(Dec) in R&D Allocation,” which equates to TP R&D); id.
NNL in turn owns 100% of the equity of each of NNI, the Nortel Group’s operating company in the United States; NNUK, the Nortel Group’s operating company in the United Kingdom; and NN Ireland, the Nortel Group’s operating company in Ireland; and 91.17% of the equity of NNSA, the Nortel Group’s operating company in France.22 As of the Petition Date, the remaining 8.83% of NNSA was owned by Nortel Networks International Finance & Holding, B.V. TR22075 (Dec.
The Claimants allege that from 2000 onward, NNL and NNI set in motion the “Irish Cash Repatriation Strategy,” through which NNL became the direct shareholder in NNIR and obtained multiple eight- and nine-figure interest-free loans and dividend payments from NN Ireland.
As the Nortel Group informed the CRA, IRS and Inland Revenue9, the licenses to exploit NT Technology held by NNI, NNUK, NN Ireland and NNSA under the last R&D CSAs rendered them economic owners of Nortel’s patents and other covered technology within their respective designated exclusive territories: “From an economic standpoint, each R&D cost sharing participant could be considered to ‘own’ the NT Technology as it related to its specific region.” TR11055 (Horst Frisch Report) at 10.
The amount of the Italian Registration Duty has to be assessed by the relevant Italian tax authorities and currently is, as to the Italian Subsidiary Guarantee, 0.50% of Euro 20 million and, as to the Pledge Agreement entered into by NN Ireland, 0.50% of the value of such pledge.
This meant that NNUK thereby also became the owner of all NNIFH BV’s shares in all of the EMEA Entities, except NN France SA and NN Ireland.