Yes, but in the case of that hotel you mentioned in Barbados, it can be said that there are commercial activities going on in Barbados, Bermuda or wherever. But with a company that does not really conduct commercial activities, and has nothing but a legal structure in order to avoid paying taxes under the current laws, could the government of the day use the fact that no real commercial activities are being conducted to deny tax-exempt status when the profits are repatriated?
On June 7th, 2007. See this statement in context.