Stategic Forecasting Inc. I LLUSTRATION OF J OINT V ENTURE & P ROPOSED R ESTRUCTURING DRAFT OF...

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Stategic Forecasting Inc. ILLUSTRATION OF JOINT VENTURE & PROPOSED RESTRUCTURING DRAFT OF 5/17/2011 CONFIDENTIAL PRIVILEGED COMMUNICATION ATTORNEY WORK PRODUCT

description

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 of Stategic Forecasting Inc. I LLUSTRATION OF J OINT V ENTURE & P ROPOSED R ESTRUCTURING DRAFT OF...

Page 1: Stategic Forecasting Inc. I LLUSTRATION OF J OINT V ENTURE & P ROPOSED R ESTRUCTURING DRAFT OF 5/17/2011 CONFIDENTIAL PRIVILEGED COMMUNICATION ATTORNEY.

Stategic Forecasting Inc.

ILLUSTRATION OFJOINT VENTURE & PROPOSED RESTRUCTURING

DRAFT OF 5/17/2011CONFIDENTIALPRIVILEGED COMMUNICATIONATTORNEY WORK PRODUCT

Page 2: Stategic Forecasting Inc. I LLUSTRATION OF J OINT V ENTURE & P ROPOSED R ESTRUCTURING DRAFT OF 5/17/2011 CONFIDENTIAL PRIVILEGED COMMUNICATION ATTORNEY.

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

Page 3: Stategic Forecasting Inc. I LLUSTRATION OF J OINT V ENTURE & P ROPOSED R ESTRUCTURING DRAFT OF 5/17/2011 CONFIDENTIAL PRIVILEGED COMMUNICATION ATTORNEY.

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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.

Page 4: Stategic Forecasting Inc. I LLUSTRATION OF J OINT V ENTURE & P ROPOSED R ESTRUCTURING DRAFT OF 5/17/2011 CONFIDENTIAL PRIVILEGED COMMUNICATION ATTORNEY.