stategic forecasting inc. i llustration of j oint v enture & p roposed r estructuring draft of...
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3 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.TRANSCRIPT
Stategic Forecasting Inc.
ILLUSTRATION OFJOINT VENTURE & PROPOSED RESTRUCTURING
DRAFT OF 5/17/2011CONFIDENTIALPRIVILEGED COMMUNICATIONATTORNEY WORK PRODUCT
Stratcap Funds
2
Stratfor
Shareholders
New Stratfor
StratforNewco
Stratcap Management Companies
Stratcap Funds
Morenz GroupMorenz Member
GeorgeFriedman
20%
70%
5%
5%
90% 10%
Tax Legend
Corporation
Partnership
Multiple Entities & Individuals
Various%
Newco
90%
10%
100% Economic0% Voting
0% Economic100% Voting
3
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.