The UK-registered HEC was replaced after about 18 months by the Operation and Transport Corporation, Ltd. (OTC). This entity was incorporated in Panama – a well-known tax haven – in February 1968 by Hubbard, his wife and Leon Steinberg, a Sea Org member who served as supercargo aboard one of Hubbard's ships. Immediately after the trio incorporated OTC, they resigned and were replaced by three Sea Org members. Hubbard, however, remained very much in control; he held ninety-eight of the 100 issued shares and the US Court of Claims later found OTC to be a "sham corporation".
