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This confidential communication outlines a joint venture and proposed restructuring for Stratcap Funds shareholders. The restructuring aims to clarify the economic and voting rights distribution among stakeholders, proposing configurations where Stratfor Newco retains a 90% economic interest while offering a 10% voting share to others. A detailed overview of the management companies involved and tax compliance notice is included, ensuring adherence to IRS regulations. This document is meant to guide and inform the strategic direction of Stratcap in alignment with shareholder interests.
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DRAFT OF 5/17/2011 CONFIDENTIALPRIVILEGED COMMUNICATIONATTORNEY WORK PRODUCT Stategic Forecasting Inc. Illustration ofJoint Venture & Proposed Restructuring
Stratcap Funds Shareholders 100% Economic0% Voting 0% Economic100% Voting StratforNewco Stratfor Morenz Member Morenz Group GeorgeFriedman 90% 10% Newco New Stratfor 90% 5% 10% 70% 5% 20% Stratcap Management Companies Various% Stratcap Funds
Circular 230 Notice To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or tax-related matters addressed herein.