NEW September 2016 Edition of Mergers, Acquisitions, and Buyouts by Martin D. Ginsburg, Jack S. Levin, and Donald E. Rocap
|
|
- Rosalind Pope
- 5 years ago
- Views:
Transcription
1 NEW September 2016 Editio of Mergers, Acquisitios, ad Buyouts by Marti D. Gisburg, Jack S. Levi, ad Doald E. Rocap We are proud to eclose the September 2016 editio of Gisburg Levi ad Rocap Mergers, Acquisitios, ad Buyouts. Here is a summary of major developmets reflected i the ew editio, writte by co-authors Jack S. Levi ad Doald E. Rocap, seior parters i the iteratioal law firm of Kirklad & Ellis LLP. Highlights of the New Editio l Charitable doatio of T stock immediately before P s taxable acquisitio of T. If A, a T shareholder (either miority or eve majority cotrollig shareholder), cotributes T stock to charity at approximately the same time as P is acquirig T i a taxable trasactio, (1) is A etitled to a charitable deductio for the FV of the doated T stock without also recogizig the gai iheret i her T stock or (2) is A taxed o her iheret gai i the T stock ad treated as cotributig to charity the proceeds from the stock sale to P? Uder log-stadig precedet, icludig a reveue rulig, A is ot taxed o her iheret gai i the T stock, uless at the time the stock is doated to charity A (the door) is uder, ad thus the doee charity takes the T stock subject to, a bidig legal obligatio (the P-T acquisitio agreemet) to sell, redeem, or otherwise dispose of the T stock. However, if at doatio time A s stock is already subject to such a bidig legal obligatio, A is taxed o the iheret gai i the stock (eve if P has the right to call off the acquisitio should T suffer a material adverse chage before cosummatio). Thus, if at the time of the doatio A has ot yet etered ito a bidig legal obligatio, the tax law does ot recharacterize the trasactio merely because A Copyright 2016 CCH Icorporated. All Rights Reserved. 1 MORE
2 iteds (ad expects) the doee charity to, ad i fact the doee charity does, promptly avail itself of the opportuity to covert the doated stock to cash. The same priciple applies (i.e., A is ot taxed o the appreciatio i her T stock) if the taxable sale of T to P is ot structured as a simple sale of T s stock to P (as discussed above) but utilizes aother trasactioal format: T is beig sold to P via a taxable cash merger betwee P ad T (forward or reverse), ad A s charitable cotributio of T stock occurs before T s shareholders have voted o the T-P merger, T is beig sold to P via a cash teder offer (i.e., P is makig a teder offer for T s stock to be followed by a squeeze-out cash merger of P ad T [forward or reverse]), ad A s charitable cotributio of T stock occurs before a majority of T s shares have bee tedered ito P s teder offer, or T is sellig its assets to P ad distributig the proceeds to its shareholders i a taxable liquidatio ad A s charitable cotributio of T stock occurs before a majority of T s shareholders have ratified the liquidatio pla. See discussio at l Tax-free spi-offs. Uwid of high-vote/low-vote structure. Code 355 dealig with tax-free spi-offs (or split-ups) requires that a distributig corporatio ( D ) ow ad distribute a amout of stock of its cotrolled subsidiary ( C ) represetig C s cotrol, which is defied to mea (a) stock represetig 80% or more of the votig power of all C s outstadig stock ad (b) 80% or more of each class of C s o-votig stock. Where D ows (a) less tha 80% of C s total votig power or (b) less tha 80% of a class of C o-votig stock, IRS ruligs have log permitted D to gai cotrol of C before the spi-off by (a) recapitalizig a class of C votig stock ito a higher votig class so that D i the aggregate holds more tha 80% of C s votig power ad/or (b) recapitalizig a class of C o-votig stock i which D holds less tha 80% ito a class that holds a low amout of votig power. IRS issued several private letter ruligs permittig C, followig the spi-off, to uwid the high-vote/low-vote structure that had bee created to meet the cotrol defiitio as described above. However, i 2013, IRS aouced that it would o loger issue letter ruligs o such high vote/low vote structures while it studied issues associated with such ruligs. I 7/16 IRS published a reveue procedure reportig o the results of that study ad providig a safe harbor with respect to the potetial uwid of these 2
3 structures. Specifically, the reveue procedure applies to a series of trasactios i which: (1) D ows a amout of C stock ot satisfyig the cotrol requiremet, (2) C recapitalizes its shares, as a result of which D acquires cotrol of C through the creatio of high-vote ad low-vote classes of stock (the Recapitalizatio ), (3) D distributes C stock i a proposed Code 355 distributio, ad (4) thereafter C desires to effectively uwid the dual class structure created i the Recapitalizatio. I these cases, IRS will ot assert that the Recapitalizatio lacks substace such that D failed to satisfy the cotrol test so log as either: 5 o actio is take by C (or its directors, officers, or cotrollig shareholders) to uwid the Recapitalizatio at ay time prior to 24 moths after the distributio or 5 the Recapitalizatio uwid occurs pursuat to a trasactio with a third party ad there was o agreemet, uderstadig, arragemet, or substatial egotiatios or discussios regardig the third-party trasactio or a similar trasactio durig the 24 moths edig o the distributio date. This guidace provides welcome certaity to D cosiderig a dual class Code 355 distributio of C with respect to future ability to ratioalize C s capital structure if warrated by market ad busiess cosideratios. The 7/16 Rev. Proc., by its terms, does ot appear to apply where D ows historic cotrol of C ad recapitalizes C s shares ito a high-vote/low-vote structure i order to (i) retai more tha 20% (by value) of C s stock for dispositio subsequet to a Code 355 distributio or (ii) issue more tha 20% (by value) of C s stock i a IPO prior to a Code 355 distributio while maitaiig such cotrol. IRS officials have, however, stated i public forums that the 7/16 Rev. Proc. does exted to such situatios. The authors hope IRS will supplemet the Rev. Proc. to cofirm this poit ad, i doig so, cosider allowig a less-tha-2-year uwid period where D s cotrol of C is historic. See discussio at Active trade or busiess test. A 2/15 reveue procedure expressed cocer regardig spi-offs with small active trades or busiesses, statig that they may preset evidece of device, lack a adequate busiess purpose, or violate other Code 355 requiremets ad/or circumvet the repeal of the Geeral Utilities doctrie. 3 MORE
4 While it studied these issues, IRS aouced that it would ot ormally issue private letter ruligs where the active trade or busiess of D or C represeted less tha 5% of the corporatio's total gross assets. I 7/16, IRS issued proposed regulatios, which, if fialized i proposed form, would require that the FV of active trade or busiess gross assets of each of D ad C must represet at least 5% of the FV of that etity s total gross assets, calculated by dividig the FV of a etity s Five-Year-Active-Busiess Assets by the FV of the etity s Total Assets. A etity s Five-Year-Active-Busiess Assets would be its gross assets used i oe or more busiesses. This rule would put a premium o havig a certai level of good 5-year active trade or busiess assets. If D or C is egaged i a substatial active trade or busiess that does ot meet the 5-year requiremet, such active trade or busiess assets would fall o the bad side of this calculatio. The test for each of D ad C would be measured at the D separate affiliated group ad C separate affiliated group level, ad although iterests i parterships geerally would ot cout as busiess assets, a look-through rule would apply for parterships through which D or C is cosidered to be egaged i oe or more 5-year active trades or busiesses. Active trade or busiess assets would iclude reasoable amouts of cash ad cash equivalets held as workig capital or required to be held (x) for regulatory purposes, (y) by cotract, or (z) as prudet reserves. Total Assets would be the Five-Year-Active-Busiess Assets plus all of the corporatio s other assets. A corporatio s Five-Year-Active-Busiess Assets ad other assets would be determied ad categorized as of immediately after the distributio. The asset FV could, however, be measured (i) immediately before the distributio, (ii) o ay date withi the 60-day period before the distributio, (iii) o the date that a agreemet bidig o D at all times thereafter regardig the distributio is etered ito, or (iv) o the date of a public aoucemet or filig with SEC with respect to the distributio. If D ad C do ot calculate ad report these values cosistetly, IRS would determie the values as of immediately prior to the distributio (uless IRS determies that the use of such date is icosistet with 355 s purposes). For purposes of Code 355 geerally, a five-year active trade or busiess ca iclude assets acquired less tha five years before a distributio where the assets costitute a expasio of a pre-existig busiess. However, the proposed regulatios iclude a broad ati-abuse rule which would disregard ay trasactio or series of trasactios (e.g., a expasio of a existig busiess) udertake with a pricipal purpose of avoidig the 5%-active-trade-or-busiess requiremet. I additio, the rules would apply separately to each spi-off, with o exceptio 4
5 for a iteral spi-off, where these rules could be problematic eve i a otherwise o-abusive situatio. These 7/16 proposed regulatios would geerally apply to a trasactio occurrig o or after the date fial regulatios are issued, but would ot apply to a distributio (i) pursuat to a bidig agreemet, resolutio, or other corporate actio occurrig prior to the date fial regulatios are issued, (ii) described i a rulig request submitted o or before 7/15/16, or (iii) publicly aouced or described i a SEC filig o or before the date fial regulatios are issued. Importatly, the preamble to the proposed regulatios states that Cogress did ited that a greater tha de miimis active trade or busiess is required i order to accomplish a tax-free spi-off. Despite failig to discer that itet over decades of its previous Code 355 iterpretatios of Cogressioal itet, IRS appears to be takig the positio that a certai level of active trade or busiess assets has always bee required. Give this positio, from ad after 7/15/16 practitioers should be wary of attemptig a Code 355 distributio with a active trade or busiess that does ot meet the 7/16 proposed regulatios miimum active busiess threshold requiremets. See discussio at Device test. To qualify as a tax-free spi-off, D s distributio of C s stock must ot be a device for the distributio of D s or C s E&P. The device test was desiged to prevet shareholders from extractig earigs from D i a CG trasactio without sigificatly reducig their percetage equity iterest i D. IRS regulatios state that the determiatio of whether a corporate separatio costitutes a device is based o all the facts ad circumstaces, icludig the presece of certai eumerated device ad o-device factors. 7/16 proposed regulatios would impose ew device tests where D or C holds substatial o-busiess assets. The preamble to the proposed regulatios expresses IRS belief that, where D is publicly traded, taxpayers have bee givig udue weight to this fact as a o-device factor ad over-emphasizig what IRS views as weak busiess purposes to offset evidece of device resultig from the separatio of o-busiess assets from busiess assets, eve whe pressure from public shareholders was a catalyst for the trasactio. I additio IRS believes that a trasactio is geerally a device where either D or C has a large percetage of o-busiess assets or D s ad C s respective percetages of such assets differ substatially. To address these cocers, the 7/16 proposed regulatios would add two ew device factors : (1) Owership of o-busiess assets by D or C represetig 20% or more of total assets ad 5 MORE
6 (2) A differece i the percetage of total assets represeted by o-busiess assets betwee D ad C (uless the differece is below 10% or, i a split-off sceario, is attributable to the eed to equalize C s ad D s values). Uder the proposed regulatios, the term busiess assets would mea gross assets used i oe or more active trades or busiesses. Helpfully, IRS clarified that busiess assets would iclude reasoable amouts of cash ad cash equivalets held as workig capital or required to be held (a) for regulatory purposes, (b) by cotract, or (c) as prudet reserves. I additio, the percetage of busiess assets geerally would be measured at the separate affiliated group level. Although partership iterests ad corporate stock would geerally be treated as o-busiess assets, a look-through rule would apply for (i) a partership coductig a active trade or busiess i which D or C is deemed to egage uder Code 355(b) ad the regulatios ad (ii) stock of a corporatio i which either the C separate affiliated group or D separate affiliated group ows a 50%-or-greater iterest. A etity s busiess ad o-busiess assets would be idetified ad classified as of immediately after the distributio. The asset FV could, however, be measured (i) immediately before the distributio, (ii) o ay date withi the 60-day period before the distributio, (iii) o the date that a agreemet bidig o D at all times thereafter regardig the distributio is etered ito, or (iv) o the date of a public aoucemet or SEC filig with respect to the distributio. If D ad C do ot calculate ad report these values cosistetly, IRS would determie the values as of immediately prior to the distributio (uless IRS determies that the use of such date is icosistet with Code 355 s purposes). Fially, although a strog busiess purpose would remai a o-device factor, the 7/16 proposed regulatios would require that, for a busiess purpose to overcome evidece of device related to differeces betwee D s ad C s busiess/ o-busiess asset ratios, there must be a strog busiess purpose relatig directly to such differece. Uder the 7/16 proposed regulatios, certai purported Code 355 distributios would be a per se device, o matter the stregth of the busiess purpose or other o-device factors. This largely mechaical per se device rule (a) would apply if the o-busiess assets of either D or C equal or exceed two-thirds of its total assets ad (b) the would compare the o-busiess asset percetages of each of D ad C. The test would be measured by referece to three bads or rages of o-busiess asset percetages of the corporatio (D or C) that has the higher percetage of o-busiess assets. If the o-busiess asset percetage of the other corporatio is less tha the specified miimum o-busiess asset percetage for the applicable bad, the the trasactio would be a per se device. 6
7 Bad 1 Bad 2 Bad 3 No-busiess asset percetage of D/C Miimum permitted o-busiess asset percetage of other corporatio Equal to or greater tha %, but less tha 80% = Equal to or greater tha 80%, but less tha 90% Equal to or greater tha 90% 30% 40% 50% The rules for determiig the requisite percetages of busiess ad o-busiess assets would be the same as those that apply for purposes of the proposed ew device factors, described above. Proposed adoptio of this per se device rule would make applicatio of the device test more rigid ad may ot take ito accout all circumstaces or good busiess reasos for certai asset divisios. However, IRS appears to be of the view that the burdes resultig from, ad the rigidity of, these mechaical tests are warrated whe two-thirds or more of D s or C s assets cosist of o-busiess assets. The proposed regulatios provide two importat exceptios to this per se device rule that should appropriately free most cash-rich split-offs to corporate shareholders (that pass muster uder Code 355(g)) from applicatio of such rule. First, the per se device rule would ot apply if the distributees i the trasactio are domestic (U.S.) corporatios that would be eligible for the 80% dividedsreceived deductio uder Code 243(a) or 245(b). Secod, the per se device rule ordiarily would ot apply to certai trasactios with importat o-device idicia, described uder Reg (d)(5), such as a trasactio i which D ad C lack E&P or a split-off trasactio i which it is clear that the distributio if taxable would otherwise qualify as a o-pro rata redemptio to all D shareholders uder Code 302(a). See discussio at ad l LossCo (troubled compay) debt restructurig tax ramificatios from trasferrig property to creditor i paymet of full-recourse or o-recourse debt. If LossCo is uable to pay its creditors (or is i bakruptcy), some or all of its debts are typically modified, restructured, or satisfied i a maer that alleviates LossCo s fiacial burde, geerally ivolvig compromises by LossCo s creditors ad possibly by LossCo s shareholders. Full-recourse debt. Where, as a part of such a debt restructurig, LossCo trasfers assets (e.g., real estate) to a creditor i exchage for cacellatio of LossCo full recourse idebtedess which exceeds i amout the trasferred assets FV, the 7 MORE
8 geeral rule is that LossCo is treated, for tax purposes, as sellig the property for a amout equal to the property s FV (ot for the larger amout of idebtedess beig cacelled). Thus, LossCo recogizes Code 1001 gai (or loss) o dispositio of the property equal to the property s FV mius LossCo s tax basis i the property. I additio, LossCo also recogizes debt cacellatio ( DC ) which i tur becomes either cacellatio of debt icome ( CODI ) or attribute reductio ( AR ) equal to the amout of debt cacelled mius the property s FV. No-recourse debt. Where, however, LossCo s debt is o-recourse (i.e., the creditor s claim is limited to the property securig the debt), LossCo is viewed for tax purposes as sellig the asset to the creditor for a amout equal to the debt s adjusted issue price (i.e., face amout, with adjustmets for uamortized OID, uamortized OIP, ad upaid accrued iterest), ad LossCo does ot recogize ay DC. Ofte LossCo would prefer DC rather tha Code 1001 taxable gai because LossCo ca ofte treat DC as AR (which does ot costitute immediate taxable icome), rather tha as gai o dispositio of the asset (which does costitute immediate taxable icome). No-recourse debt created through orgaizatioal structure. The o-recourse ature of debt typically results from limitatios i the applicable loa agreemet, for example, a provisio that, i the evet of a default, the creditor s claim agaist LossCo is limited to LossCo s iterest i the asset (e.g., real estate) securig the loa. However, o-recourse debt ca also be created through orgaizatioal structure. If LossCo has a subsidiary etity that is disregarded for federal icome tax purposes (e.g., a LLC 100% of the equity iterests of which are owed by LossCo), the disregarded etity s debt which is ot guarateed by LossCo is geerally treated as o-recourse LossCo debt for federal icome tax purposes sice (1) the subsidiary is disregarded, (2) the debt is viewed for federal tax purposes as LossCo s debt, ad (3) LossCo does ot have full recourse liability for the debt. This is true eve if the debt is full recourse to the disregarded LLC. Thus, LossCo recogizes Code 1001 gai (or loss) o dispositio of the property equal to the differece betwee disregarded-llc s tax basis i the property ad the full amout of LLC s adjusted issue price for the debt (i.e., the property s FV is ot relevat). Hece oe of LossCo s gai costitutes DC ad oe qualifies for the AR rules. See discussio at ad (2). 8
9 l 2016 proposed Code 385 debt-equity regulatios. 4/16 complex proposed regulatios would madate equity characterizatio for certai related party debt istrumets, without regard to traditioal subjective debt-equity factors (e.g., DER, overlap, projected ability to service the debt, reasoable debt terms, act like creditor). These regulatios would apply oly i limited circumstaces: to debt istrumets issued betwee corporatios bearig a 80%-or-greater paret-subsidiary or brother-sister relatioship (but ot part of a sigle group filig a U.S. cosolidated federal icome tax retur), referred to as a expaded group. These rules would apply where, for example, a U.S. corporatio issues a debt istrumet to its 80%-or-greater foreig paret corporatio or where a partership ows 80% or more of the stock of two U.S. corporatios, oe of which issues a debt istrumet to its sister corporatio. The proposed regulatios would, with limited exceptios (icludig a exceptio for debt istrumets ot exceedig $50 millio i the aggregate), automatically treat a debt istrumet as equity if issued by oe expaded group member to aother: (a) as a divided or redemptio distributio, (b) i exchage for stock of aother group member, or (c) i exchage for property of aother group member i certai types of asset reorgaizatios. The same treatmet would apply if a debt istrumet is issued by oe expaded group member to aother member for cash or other property, with a pricipal purpose of fudig a distributio or acquisitio described i (a) through (c). The proposed regulatios would treat debt as issued with a pricipal purpose of fudig such a distributio or acquisitio if the debt is issued durig the period begiig 36 moths before, ad edig 36 moths after, the applicable distributio or acquisitio, with a arrow exceptio for certai debt issued for property i the ordiary course of busiess. This portio of the regulatios would apply to debt istrumets issued after 4/3/16. To facilitate IRS audits, the proposed regulatios would also impose ew recordkeepig requiremets for a debt istrumet issued betwee members of a expaded group (as defied above) if (regardless of the type of trasactio beig fiaced): (1) the stock of ay group member is publicly traded, (2) a group fiacial statemet shows total assets exceedig $100 millio, or (3) a group fiacial statemet shows total aual reveue exceedig $50 millio. 9 MORE
10 Such a debt istrumet would automatically be treated as equity uless: (a) documetatio is prepared withi 30 days of the debt istrumet s issuace evidecig a bidig obligatio to repay the fuds, the creditor s rights to eforce the terms of the istrumet, ad a reasoable expectatio of the borrower s ability to repay the istrumet o its terms ad (b) ogoig documetatio is prepared ad maitaied evidecig a cotiuig ad geuie debtor/creditor relatioship, icludig paymets of iterest ad pricipal ad, if applicable, eforcemet actios upo default. This documetatio portio of the regulatios would apply to a debt istrumet issued after the regulatios are fialized. See discussio at l Reductios i compay s GAAP earigs because of stock grats, sales, or optios to executives. Stock sale or award. Whe a compay makes a stock sale or award to a executive, (1) the compay s accoutig et icome is reduced (over the executive s service period, geerally the vestig period) by the compesatio expese, which i tur is equal to the stock s FV at the time of sale or award less the price (if ay) paid by the executive ad (2) the compay s accoutig et icome is icreased by its expected tax savig from ay tax deductio created by the stock sale or award, so that the compay s accoutig et icome is reduced by such compesatio expese et of the tax beefit. Stock optio. Whe a compay grats a stock optio to a executive, (1) the compay s accoutig et icome is reduced (over the executive s service period, geerally the vestig period) by the compesatio expese, which i tur is equal to the optio s FV at the grat date, takig ito accout both (a) the spread (if ay) at grat betwee the stock s FV ad the optio price ad (b) the FV of the optio privilege, i.e., the value to a executive from deferrig the stock purchase decisio ad paymet of the optio price (geerally 20% to 40% of the optio stock s grat date FV for a optio that is ot sigificatly i-the-moey at grat), ad (2) the compay s accoutig et icome is icreased by its expected tax savig from ay tax deductio created by the optio grat ad exercise, so that the compay s accoutig et icome is reduced by such compesatio expese et of the tax beefit. Tax savig calculatio. Uder pre-3/16 GAAP rules, the tax savigs from ay tax deductios i excess of the compay s accoutig expese ( excess tax beefits ) have geerally bee credited directly to et worth as paid i capital ad do ot flow through the compay s icome statemet. However, GAAP rules adopted i 3/16 elimiate the cocept of excess tax beefits, effective 1/17 for a public 10
11 compay usig the caledar year ad 1/18 for a private compay usig the caledar year, with early adoptio permitted. Uder the ew 3/16 rules, the compay is required to adjust its tax beefits (geerally calculated pursuat to Code 83, 409A, ad 404(a)(5)) from a sale, award, or optio grat ad exercise as estimated at grat to reflect its actual tax beefits (e.g., because of FV fluctuatios betwee sale/grat ad vestig if o 83(b) electio was made for a stock sale/award or betwee grat ad exercise/ vestig for a optio) ad such adjustmets, whether positive (the compay s actual tax beefits are greater tha estimated) or egative (the compay s actual tax beefits are smaller tha estimated), flow through the compay s icome statemet ad affect GAAP et icome. Vestig rules. A executive s stock or optio is frequetly subject to vestig based o a service coditio (requirig the executive to provide services to the compay) or a performace coditio (requirig both (i) the executive to provide services to the compay ad (ii) satisfactio of a performace target relatig to the employer s operatios or activities, either durig or after the requisite service period). Stock or optio FV is ot reduced based o the possibility the executive will ot vest i the award ad hece will forfeit the compesatio; rather, compesatio expese is recogized oly for a award that ultimately vests. Uder GAAP rules adopted i 3/16 (effective 1/17 for a public compay ad 1/18 for a private compay as described above), the compay must either (i) estimate the portio of its awards expected to vest based o the provisio of services ad subsequetly adjust such estimate from time to time i light of vestig expectatios ad ultimately based o actual vestig results or (ii) take ito accout forfeitures based o failure to provide services as they actually occur. Prior to the 3/16 rules effective date a compay must estimate the forfeitures expected to occur based o the failure to provide services ad adjust the estimate from time to time based o vestig expectatios ad actual forfeitures. Payig withholdig tax with ew shares. A award may permit the compay to withhold shares to meet the employer s miimum statutory [tax] withholdig requiremets without causig the award to be treated as a liability for accoutig purposes (which would ivoke harsher accoutig rules). Uder pre-3/16 GAAP rules, if a amout i excess of the miimum statutory requiremets is withheld, or may be withheld at the employee s discretio, the etire award shall be classified... as a liability for accoutig purposes. 11 MORE
12 However, GAAP rules adopted i 3/16 permit shares to be withheld at a rate up to the maximum idividual statutory tax rate i the applicable jurisdictios for federal, state, ad local icome ad payroll taxes, without causig the award to be treated as a liability. Subject to this commo percetage cap applicable to all employees taxed i a give jurisdictio, the ew rules (a) do ot require that the employer actually withhold the same percetage amout from each employee ad (b) allow a employee some discretio i specifyig the amout of withholdig with respect to his award. Thus, uder these 3/16 GAAP rules, the employer may withhold shares i a amout up to the taxes the employee would owe with respect to the award, determied usig the maximum idividual statutory tax rate i the applicable jurisdictios, ad the award could still be treated as a equity istrumet (allowig the more desirable accoutig rules described above to be utilized). However, the ew 3/16 rules apply oly to a employer that has a statutory tax withholdig obligatio (e.g., ot to a partership, for a award issued to a parter). The 3/16 rules are effective 1/17 for a public compay usig the caledar year ad 1/18 for a o-public compay usig the caledar year, with early adoptio permitted. See discussio at , , l Proposed IRS regulatios attack PE/VC fud maagemet fee reductio i exchage for ehaced LTCG allocatio, i.e., waived maagemet fee. Waived maagemet fee cocept. GPs of some PE/VC fuds opt to reduce the maagemet fee payable by the fud to the GP (which is taxable as OI) i exchage for a ehaced allocatio of fud profits taxable at lower rates as LTCG ad/or QDI. This maagemet fee reductio is most commoly structured as a cashless cotributio arragemet, uder which GP ca satisfy a portio of its capital commitmet to the fud by makig deemed (or cashless ) cotributios to the fud equal to the amout by which the maagemet fee was reduced. GP the receives subsequet fud distributios as if it had actually made the cashless cotributios to the fud i cash (i.e., amouts represetig a retur of the cashless cotributio plus or mius the positive or egative ivestmet retur o the cashless cotributio), coditioed o the fud earig sufficiet profits to support characterizatio of these distributios as a iterest i future fud profits (LTCG ad QDI). 1 1 Less ofte, GP receives a capped iterest i future fud allocatios ad distributios equal to oly the fee reductio (i.e., cashless cotributio) amout. 12
13 I some cases the etire GP waiver is made upfrot at the time of fud formatio, while i other cases GP reserves the right to elect periodically to waive i advace a portio of the maagemet fee i exchage for such a ehaced allocatio of fud future appreciatio. As log as there is meaigful ecoomic risk that GP may ot receive sufficiet allocatios of fud profits to make GP whole for the foregoe maagemet fee (e.g., whe the allocatio equal to the foregoe maagemet fee is out of aual et profits ad may ot be take from appreciatio i fud assets existig at the time of the maagemet fee-reductio electio, but rather may be take oly from subsequet [i.e., post-maagemet-fee waiver] appreciatio), this techique should covert maagemet fee icome which would have bee taxed as OI ito a profits iterest i the fud, so that the character of the item of icome allocated to GP geerally LTCG ad QDI flows through to GP. 7/15 IRS proposed regulatios. 7/15 proposed IRS regulatios would treat such a fud maagemet fee reductio arragemet as a disguised paymet for services, resultig i OI characterizatio, uless the arragemet meets a high etrepreeurial risk stadard. The proposed regulatios would create a presumptio of isufficiet etrepreeurial risk where GP s profit allocatio is: (i) capped i amout, (ii) measured by gross icome, rather tha et icome, (iii) reasoably determiable i amout, or (iv) eve if ot reasoably determiable i amout, desiged to assure that sufficiet et profits are highly likely to be available to make the allocatio to GP. Uder traditioal maagemet fee reductio arragemets, GP s right to receive or retai distributios i respect of waived fees has bee coditioed o the fud recogizig sufficiet CG or QDI i oe or more years i which the fud geerates overall et icome (igorig years i which the fud has et losses). Uder the proposed regulatios, profit allocatios would be viewed as highly likely to be available ad hece presumed to be disguised paymets for services (i.e., OI) uless profits allocated to GP uder the arragemet are limited to the fud s et profits over a exteded period (e.g., the fud s cumulative et icome over the fud s etire life). The proposed regulatios would apply to arragemets etered ito or modified (icludig by makig ew fee waivers) after fial regulatios are issued (expected sometime i late 2016). 13 MORE
14 For arragemets etered ito before issuace of fial regulatios (ad ot thereafter modified), the regulatory preamble asserts that the proposed regulatios geerally reflect Cogressioal itet, although there appears to be little support i pre-existig law for recharacterizig a properly structured cashless cotributio arragemet as a disguised paymet for services. Future modificatio of Rev. Proc The preamble to the 7/15 proposed regulatios also aouced that IRS iteds to modify Rev. Proc (which allows a partership profits iterest issued to a service parter to be valued at its $0 LV, rather tha its speculative FV) so that the Rev. Proc. would ot apply this taxpayer-favorable rule to a profits iterest issued i cojuctio with a parter foregoig paymet of a amout that is substatially fixed. If the Rev. Proc. is so modified, IRS could assert that a fud GP eterig ito a fee reductio arragemet must recogize immediate OI equal to the FV of the profits iterest received by GP eve if this profits iterest satisfies the high etrepreeurial risk stadard of the proposed disguised sale regulatios. See discussio at (6). l 6/16 IRS liberalizatio of Code 409A regulatios. Exceedigly complex ad legthy Code 409A regulatios madate immediate OI recogitio plus a 20% additioal pealty tax (producig a 59.6% maximum tax rate) o may types of OI compesatio to a service provider paid o a deferred basis. 6/16 proposed (pro-taxpayer) regulatory amedmets (which taxpayers may immediately rely upo) liberalize a few of Code 409A s may highly techical (ad ati-taxpayer) rules, icludig: the uforeseeable evet rule, permissible distributio triggers, the ati-abuse rule, severace arragemets, ad service recipiet stock rules. See discussio at l Double-tax pealty o REIT built-i gai exteded to 10 years. A C corp (with appreciated assets) electig to be taxed as a REIT (or a existig REIT acquirig appreciated assets from a C corp with carryover basis [ COB ]), is geerally, by virtue of Code 337(d) ad the regulatios thereuder, subject to Code 1374 s etity-level corporate pealty tax o such built-i gai ( BIG ) to the extet recogized withi a 14
15 specified period (the recogitio period ) followig the C corp s REIT electio (or the REIT s COB asset acquisitio from a C corp). Prior to 2016, the recogitio period for a former C corp (with appreciated assets) electig to be taxed as a REIT (or for a REIT acquirig appreciated COB assets from a C corp) tracked the Code 1374 recogitio period for a C corp electig to be taxed as a S corp (or a S corp acquirig COB appreciated assets from a C corp), i.e., 10 years for such gai recogized before 2009, temporarily reduced to 7 years for such gai recogized i 2009 ad 2010, the temporarily reduced to 5 years for such gai recogized i 2011 through 2014, the permaetly reduced to 5 years for gai recogized i 2015 ad thereafter, as discussed i the S corp cotext at While the legth of the S corp recogitio period (10 years, the 7 years, the 5 years) is established by statute (Code 1374), the legth of the REIT recogitio period has always bee established by regulatios which util 6/16 simply icorporated by referece the S corp 1374 statutory recogitio period. Ideed, the legislative history of the 12/15 legislatio which made permaet the S-corp year recogitio period ackowledged that Uder curret Treasury regulatios, these [Code 1374] rules, icludig the five-year recogitio period, also would apply to REITs (emphasis added). However, i 6/16 IRS surprisigly chaged course, publishig temporary 337 regulatios that, effective for a C corp with appreciated assets which coverted to a REIT after 8/7/16 (or a REIT acquirig appreciated COB assets from a C corp after 8/7/16), de-liked the regulatory REIT recogitio period from the statutory S corp recogitio period, statig i the regulatory preamble that REIT coversios will o loger be affected by [the shorteig of] the legth of the [S corp] recogitio period from 10 years to 5 years with respect to C corporatios that elect to be, or trasfer property to, S corporatios. Istead, these temporary regulatios adopted a 10-year recogitio period for a C corp with appreciated assets which elected to be taxed as a REIT after 8/7/16 (or a REIT which acquired appreciated COB assets from a C corp after 8/7/16). Applicatio of these Code 1374 priciples is madatory abset a electio (made whe the C corp with appreciated assets elects REIT status or the REIT acquires appreciated assets from a C corp) to istead recogize the iheret gai i the appreciated assets at such time. See discussio at l 2016 court decisio expads scope of ERISA group liabilities. If P acquires the requisite percetage of T s stock, ERISA geerally causes P (i.e., T s ew paret) as well as P s other subsidiaries (i.e., T s ew sister etities) to be joit ad severally liable for T s upaid ERISA pesio obligatios, which is very relevat if T should ultimately go bakrupt with uderfuded pesios. 15 MORE
16 Similarly if PE/VC fud acquires the requisite percetage of T s stock (or Newco formed ad owed by PE/VC fud acquires the requisite percetage of T s stock), ERISA may cause PE/VC fud as well as its other portfolio compaies (i.e., T s sister portfolio compaies) to be joit ad severally liable for T s upaid ERISA pesio obligatios. 2 The requisite owership is 80% or more (by vote or value where the lower-tier etity is a corporatio or by capital or profits where the lower-tier etity is a partership or LLC), except that i certai circumstaces where P (or PE/VC fud) ows 50% or more of the lower-tier etity, certai shareholders (e.g., lower-tier etity s employees who ow stock i lower-tier etity subject to restrictios) are disregarded, so that P s (or PE/VC fud s) less-tha-80% owership of the lower-tier etity could costitute requisite owership. I a 2016 district court decisio, bakrupt T (with uderfuded pesio liability) was owed 70%-30% by two PE/VC fuds (the Su fuds) formed several years apart by the same PE/VC sposor group (Su Capital). The two Su fuds did ot geerally ivest i the same portfolio compaies, had miimal commo LPs, ad if the two fuds did occasioally ivest i the same portfolio compay, the ivestmets were ot proportioate to each fud s capital. Actual structure Su GP & mgmt etities LP group #1 LP group #2 Su Fud 3 Su Fud 4 formed % 70% LLC 100% Bakrupt T formed 2005 No flow-through liability to Su fuds: uder state LLC law (which grats limited liability to a LLC s equity owers) or uder ERISA law (because either Su Fud owed requisite percetage) 2 Where the upper-tier etity (P or PE/VC fud) is a partership or LLC (rather tha a corporatio) the ERISA group liability rules apply to such upper-tier partership/llc etity oly if such uppertier etity is egaged i a trade or busiess, but there is less clarity o whether the upper-tier etity s other subsidiaries (i.e., T s sister etities) escape ERISA group liability if the upper-tier etity is ot egaged i a trade or busiess. 16
17 Because either of the two PE/VC fuds owed the requisite percetage (here 80%) of bakrupt T, the court (i holdig both PE/VC fuds liable for bakrupt T s upaid pesio obligatio) created a differet path, cocludig that both PE/VC fuds were liable because, i the district court s view, they had created a ew etity, a federal partership-i-fact (owed 70/30 by the two PE/VC fuds), to serve as the LLC s 100% ower (so the imagiary partership was [uder the ERISA rules] liable for the ERISA obligatio the LLC had iherited [uder the ERISA rules] from bakrupt T). The court the cocluded (without discussio) that the parters of the imagiary federal partership (the two PE/VC fuds) were liable (i.e., apparetly as the imagiary partership s geeral parters) for the imagiary partership s ERISA obligatio. Court s imagiary structure Su GP & mgmt etities LP group #1 LP group #2 Su Fud 3 formed 2003 Su Fud 4 formed % 70% Imagiary federal p ship 100% Flow-through liability to Su fuds: apparetly because federal p ship law cotais o statutory limited liability for imagiary geeral p ship s equity owers LLC 100% Bakrupt T The court (relyig o the Iteral Reveue Code s broad defiitio of a partership for tax purposes) reasoed that the two PE/VC fuds smooth coordiatio [was] idicative of a partership-i-fact sittig atop the LLC: a site of joiig together ad formig a commuity of iterest. However, if the court believed the two PE/VC fuds eeded a etity i order to egage i such joit activity, it is uclear why the LLC actually formed by the two PE/VC fuds (which uder state law afforded its members protectio from the LLC s upaid obligatios) rather tha a imagiary federal partership-i-fact created by the court would t serve as the repository for such coordiated activity. 17 MORE
18 Because there is i fact o federal partership law (i.e., all parterships are formed uder state, ot federal, law), it is ot surprisig that the court s federal partership-i-fact (ulike the LLC which the two PE/VC fuds actually did create) afforded o explicit equity ower-level protectio agaist upaid partership -level liabilities. Possible extesio of imagiary partership approach to ivestmets made i cocert by several wholly idepedet PE/VC fuds or by PE/VC fud alog with co-ivestors. If this 2016 district court decisio were to stad, there is a possible argumet that ivestmets by multiple ivestors i a bakrupt T (made i cocert) should be amalgamated, i.e., treated as made by a imagiary partership, eve if made: (a) by two or more wholly idepedet PE/VC fuds (or two wholly idepedet Ps) or (b) by a PE/VC fud alog with oe or more co-ivestors (e.g., oe or more of the fud s limited parters ad/or oe or more persos who are ot fud limited parters). I such case, all of the co-ivestors who cooperate i makig the ivestmet (icludig eve a 1% co-ivestor) could be viewed as GPs i a imagiary geeral partership, with full ulimited liability for bakrupt T s etire ERISA liability. See discussio at through l Avoidig T shareholder vote (ad SEC proxy rules) o secod-step squeeze-out merger of T miority shareholders after P first acquires (geerally by teder offer) substatial T stock. Where P (or S) has first acquired a portio of T s stock ad P the desires to squeeze out T s remaiig (miority) shareholders by merger, P geerally prefers to avoid a vote of T s shareholders (e.g., especially where T is a 1934 Act reportig compay ad hece required to comply with SEC s proxy rules). There are two circumstaces where a vote of T s shareholders ca be avoided: First exceptio: Delaware 253(a) ad similar exceptios i other states. Most state laws cotai a log-stadig exemptio allowig a short-form merger without ay T shareholder vote betwee a paret (here P or its subsidiary S, whichever has acquired sufficiet owership of T s stock) ad oe of its corporate subsidiaries (here T), with T s miority shareholders receivig P stock, cash, or other cosideratio as specified i the short-form-merger agreemet. The percetage of owership that P (or S) must have i T i order to utilize the short-form merger procedure (without a T shareholder vote) varies from state to state (90% beig the required percetage i Delaware). Thus, oce P (or S) has acquired the requisite stock owership i T by purchasig T stock (e.g., at least 18
19 90% i Delaware) i a teder offer or i oe or more egotiated stock purchases P (or S) ca (if such a short-form merger statute is applicable) merge with T without a T shareholder vote. Where the acquisitio is friedly ad T has adequate authorized but uissued stock, T might also grat P (or S) a top-up optio before P (or S) commeces its teder offer for (or egotiated purchase of) T stock, givig P (or S) the right (ad perhaps the obligatio) to purchase from T (typically for a ote) that umber of ew T shares which, whe combied with the T shares acquired by P (or S) i the teder offer or egotiated purchase, will be sufficiet to meet the state law threshold for a short-form merger (e.g., 90% i Delaware). Secod exceptio: Delaware 251(h). Uder a 2013 additio to Delaware law (as further ameded i 2016), a vote of T s shareholders (ad hece a 1934 Act proxy statemet) o a forward or reverse merger of T ad P (or P s subsidiary S) ca be avoided where: (a) T (orgaized as a corporatio) has more tha 2,000 shareholders or is listed o a atioal securities exchage immediately prior to executig the merger agreemet, (b) P or its corporate subsidiary ( AcquirigCorp ) makes a first-step teder or exchage offer for ay ad all T stock (although it is permissible for such teder offer to be coditioed o T shareholders tederig a miimum umber or percetage of T s shares), (c) Immediately followig the cosummatio of the [first-step teder] offer, the T stock purchased by AcquirigCorp i such [teder] offer...,together with the [T] stock otherwise owed by [AcquirigCorp] ad ay rollover stock (as defied below) is sufficiet to approve the secod-step squeeze-out merger (uder Delaware law ad T s charter), geerally more tha 50%, (d) all o-tedered T stock (other tha rollover stock) is exchaged i the secod-step squeeze-out merger for the same amout ad kid of cosideratio per share as was received by the tederig T shareholders i the teder offer (i.e., cash i the same amout per share as i the teder offer where the teder offer cosideratio was cash), (e) T is icorporated i Delaware, ad (f) the merger agreemet expressly permits or requires this procedure. Rollover stock meas T shares covered by a writte agreemet requirig such [T] shares to be trasferred...to[acquirigcorp]...i exchage for [AcquirigCorp] stock, so log as such T shares have actually bee trasferred 19 MORE
20 to AcquirigCorp o later tha immediately prior to the time the merger becomes effective. The 2016 amedmet made two salutary chages to 251(h): (i) Before the 2016 statutory amedmet, all o-tederig T shareholders were required to receive (i the squeeze-out merger) the same type ad amout of cosideratio per share for their T stock as the tederig T shareholders (i.e., requiremet (d) above but without the parethetical exceptio for rollover stock which was added by the 2016 statutory amedmet). However, after the 2016 statutory amedmet to requiremet (d), AcquirigCorp ca ow acquire T shares owed by oe or more T shareholders (icludig T executives) i exchage for [AcquirigCorp] stock, eve though all of T s other shareholders receive cash for their T shares (both i the teder offer ad i the squeeze-out merger). While the 2016 statutory amedmet allows T stock owed by ay T shareholder (ot merely by a T executive) to be treated as rollover stock, i.e., acquired by AcquirigCorp i exchage for AcquirigCorp stock, the provisio is most likely to be used i practice oly to roll oe or more key T executives T stock ito AcquirigCorp stock. (ii) After the 2016 statutory amedmet, rollover stock is geerally couted (alog with tedered T stock) toward requiremet (c) s sufficiet-t-stock-toapprove-the-merger test. Especially where P is a ew etity (formed by a PE fud to acquire T i a LBO), ew P may (after the 2016 amedmet) offer T executives (who will post-merger become key P executives) a opportuity to exchage their T shares for P shares tax-free (as part of P s Code 351 formatio ad buyout of T), thus allowig such T executives to exchage their low tax basis T stock without CG recogitio for higher FV P stock (which takes a post-merger low carryover tax basis from their old T stock). Complexity of schedulig 251(h) trasactio steps i compliace with state law fiduciary duty ad federal teder offer rules. After the 2016 Delaware amedmet became effective o 8/1/16, there is complexity i schedulig P s 251(h)-compliat two-step acquisitio of T with (x) T executives receivig P stock ad (y) other T shareholders receivig cash, i both cases i exchage for their T stock. For the reasos explaied below, the best schedule would geerally be as follows: (1) P aouces ad the (after a 20-busiess-day wait, as required by the federal teder-offer rules) closes its cash teder offer for ay ad all T stock, but T executives to whom P is plaig to offer P stock do ot teder their T shares for cash. 20
21 (2) Immediately after teder offer closig P ad such T executives eter ito a writte (rollover) agreemet obligatig P to issue P stock i exchage for such executives T rollover shares, callig for a immediate closig (e.g.) oe miute or so after sigig the rollover agreemet. (3) P ad such T executives the (oe miute or so after sigig the rollover agreemet) complete the exchage of P stock for T rollover stock (thus satisfyig Delaware 251(h) s requiremet that the T rollover stock is actually trasferred to AcquirigCorp o later tha immediately prior to the time the merger becomes effective ). (4) The merger is the cosummated immediately thereafter. This tightly scripted time schedule is ecessary i order to satisfy all the requiremets of Delaware 251(h), state law fiduciary duty, ad the federal teder offer rules: (A) P caot acquire or cotract to acquire T executives T stock before aoucig the teder offer, or ideed probably util after teder offer completio. T s executives have a state law fiduciary duty to (i) maximize the cosideratio for T s shareholders ad to (ii) treat all bidders for T equally, which would certaily appear to be breached if oe or more T executives were to joi forces with P (by cotractig to sell their T stock to P i exchage for P stock) before P s teder offer for T had bee aouced, or ideed at ay time before teder offer completio, sice other bidders competig (or plaig to compete) with P to acquire T may still be i the game ad may still top P s bid ad egage i a biddig war to acquire T. I additio, a T executive probably would ot wat to trasfer or commit to trasfer his T shares to P at P s forthcomig teder offer valuatio whe aother higher bidder for T may yet arise. Ad P may well ot wat to acquire (or commit to acquire) the T executives T stock util P is certai P s teder offer will be successful, so that P ca complete its acquisitio of 100% of T s stock. (B) P caot acquire or cotract to acquire executives T stock while the teder offer is pedig. The federal teder offer rules prohibit P (after public aoucemet of the teder offer) from acquirig or eterig ito a agreemet to acquire the executives T stock (or ideed ayoe s T stock) outside the teder offer util after the teder offer has expired. (C) P caot make two simultaeous teder offers: a stock-for-stock teder offer for the executives T stock ad a cash teder offer for the other T shareholders stock. The federal teder offer rules prohibit P from offerig disparate 21 MORE
Structuring the Selling Employee/ Shareholder Transition Period Payments after a Closely Held Company Acquisition
Icome Tax Isights Structurig the Sellig Employee/ Shareholder Trasitio Period Paymets after a Closely Held Compay Acquisitio Robert F. Reilly, CPA Corporate acquirers ofte acquire closely held target compaies.
More informationPuerto Rico Tax Incentives: The TCJA and other considerations
Puerto Rico Tax Icetives: The TCJA ad other cosideratios February 14-15, 2019 Edgar Ríos-Médez, Esq. Table of Cotets Iteratioal Tax Provisios 3 q Corporate Tax Rates ad Other Provisios 4 q Global Itagible
More informationGuide for. Plan Sponsors. Roth 401(k) get retirement right
Uited of Omaha Life Isurace Compay Compaio Life Isurace Compay mutual of omaha retiremet services Roth 401(k) Guide for Pla Sposors MUGC8764_0210 get retiremet right roth 401(k) expads your optios Drive
More informationStructuring Venture Capital, Private Equity, and Entrepreneurial Transactions
NEW 2017 Editio of Structurig Veture Capital, Private Equity, ad Etrepreeurial Trasactios W e are proud to eclose the 2017 Editio of Structurig Veture Capital, Private Equity, ad Etrepreeurial Trasactios
More informationSelected US Tax Developments
caadia tax joural / revue fiscale caadiee (2016) 64:4, 929-39 Selected US Tax Developmets Co-Editors: Peter A. Glicklich* ad Michael J. Miller** ONEROUS US REPORTING REQUIREMENTS FOR US MEMBERS OF NON-US
More informationReceipt Date. You must answer all questions in ink and the application must be signed and notarized, or it will be rejected.
Office of the New York State Comptroller New York State ad Local Retiremet System Mail completed form to: NEW YORK STATE AND LOCAL RETIREMENT SYSTEM 110 STATE STREET - MAIL DROP 5-9 ALBANY NY 12244-0001
More informationStructuring Venture Capital, Private Equity, and Entrepreneurial Transactions
NEW 2015 Editio of Structurig Veture Capital, Private Equity, ad Etrepreeurial Trasactios W e are proud to eclose the 2015 editio of Structurig Veture Capital, Private Equity, ad Etrepreeurial Trasactios
More informationFEHB. Health Benefits Coverage for Noncareer Employees
FEHB Health Beefits Coverage for Nocareer Employees Notice 426 September 2005 The Federal Employees Health Beefits (FEHB) Program permits certai ocareer (temporary) employees to obtai health isurace, if
More informationCHAPTER 2 PRICING OF BONDS
CHAPTER 2 PRICING OF BONDS CHAPTER SUARY This chapter will focus o the time value of moey ad how to calculate the price of a bod. Whe pricig a bod it is ecessary to estimate the expected cash flows ad
More informationPension Annuity. Policy Conditions Document reference: PPAS1(6) This is an important document. Please keep it in a safe place.
Pesio Auity Policy Coditios Documet referece: PPAS1(6) This is a importat documet. Please keep it i a safe place. Pesio Auity Policy Coditios Welcome to LV=, ad thak you for choosig our Pesio Auity. These
More informationCollections & Recoveries policy
Collectios & Recoveries policy The purpose of this policy is to set out the actio Ledy takes to ecourage borrowers to repay their loas withi term. This policy also serves to set out the actio Ledy takes
More informationSEC Adopts. Amendments. To The Advisers Act Custody Rule SECURITIES LAW ALERT MARCH 2010
MARCH 2010 SEC Adopts Amedmets To The Advisers Act Custody Rule The Securities Exchage Commissio ( SEC ) has adopted amedmets to Rule 206(4)-2 (the Custody Rule ) uder the Ivestmet Advisers Act of 1940
More information1031 Tax-Deferred Exchanges
1031 Tax-Deferred Exchages About the Authors Arold M. Brow Seior Maagig Director, Head of 1031 Tax-Deferred Exchage Services, MB Fiacial Deferred Exchage Corporatio Arold M. Brow is the Seior Maagig Director
More informationOsborne Books Update. Financial Statements of Limited Companies Tutorial
Osbore Books Update Fiacial Statemets of Limited Compaies Tutorial Website update otes September 2018 2 f i a c i a l s t a t e m e t s o f l i m i t e d c o m p a i e s I N T R O D U C T I O N The followig
More informationStructuring Venture Capital, Private Equity, and Entrepreneurial Transactions
NEW 2018 Editio of Structurig Veture Capital, Private Equity, ad Etrepreeurial Trasactios W e are proud to eclose the 2018 Editio of Structurig Veture Capital, Private Equity, ad Etrepreeurial Trasactios
More informationCAPITAL PROJECT SCREENING AND SELECTION
CAPITAL PROJECT SCREEIG AD SELECTIO Before studyig the three measures of ivestmet attractiveess, we will review a simple method that is commoly used to scree capital ivestmets. Oe of the primary cocers
More informationIndividual Retirement Account (IRA)
Logleaf Parters Fuds Idividual Retiremet Accout (IRA) Simple IRA Cotets BNY Mello Ivestmet Servicig Trust Compay 2 SIMPLE Idividual Retiremet Accout (IRA) Disclosure Statemet 4 SIMPLE Idividual Retiremet
More informationliving well in retirement Adjusting Your Annuity Income Your Payment Flexibilities
livig well i retiremet Adjustig Your Auity Icome Your Paymet Flexibilities what s iside 2 TIAA Traditioal auity Icome 4 TIAA ad CREF Variable Auity Icome 7 Choices for Adjustig Your Auity Icome 7 Auity
More informationHighest Daily Lifetime Seven SM Spousal Highest Daily Lifetime Seven SM
Optioal Icome beefits Highest Daily Lifetime Seve SM Spousal Highest Daily Lifetime Seve SM Daily Opportuities to Capture Greater Lifetime Icome HD Lifetime Seve ad Spousal HD Lifetime Seve Offer:» Miimum
More informationREITInsight. In this month s REIT Insight:
REITIsight Newsletter February 2014 REIT Isight is a mothly market commetary by Resource Real Estate's Global Portfolio Maager, Scott Crowe. It discusses our perspectives o major evets ad treds i real
More informationREINSURANCE ALLOCATING RISK
6REINSURANCE Reisurace is a risk maagemet tool used by isurers to spread risk ad maage capital. The isurer trasfers some or all of a isurace risk to aother isurer. The isurer trasferrig the risk is called
More informationAn Introduction to Employee Share Trust Services
A Itroductio to Employee Share Trust Services Why create a Employee ShareTrust? A public compay ca buy its ow shares ad hold them i treasury. However it has limited optios as to how it ca use those shares.
More information(Zip Code) OR. (State)
Uiform Applicatio for Ivestmet Adviser Registratio Part II - Page 1 Name of Ivestmet Adviser: Stephe Craig Schulmerich Address: (Number ad Street) 10260 SW Greeburg Rd. Ste 00 (State) (City) Portlad (Zip
More informationThe University of Chicago 457(b) Deferred Compensation Plan Enrollment Guide 2015
The Uiversity of Chicago 457(b) Deferred Compesatio Pla Erollmet Guide 2015 2 Overview 3 How to Eroll 4 Your Cotributios 5 Ivestmets 6 Receivig Your Beefits 7 Additioal Iformatio Overview The Uiversity
More informationDriver s. 1st Gear: Determine your asset allocation strategy.
Delaware North 401(k) PLAN The Driver s Guide The fial step o your road to erollig i the Delaware North 401(k) Pla. At this poit, you re ready to take the wheel ad set your 401(k) i motio. Now all that
More informationThe University of Chicago 457(b) Deferred Compensation Plan Enrollment Guide 2014
The Uiversity of Chicago 457(b) Deferred Compesatio Pla Erollmet Guide 2014 Iside 1 Overview 2 How to Eroll 4 Your Cotributios 5 Ivestmets 6 Receivig Your Beefits 8 Additioal Iformatio Overview The Uiversity
More informationCalculation of the Annual Equivalent Rate (AER)
Appedix to Code of Coduct for the Advertisig of Iterest Bearig Accouts. (31/1/0) Calculatio of the Aual Equivalet Rate (AER) a) The most geeral case of the calculatio is the rate of iterest which, if applied
More informationSummary of Benefits HAMPSHIRE COLLEGE
Summary of Beefits HAMPSHIRE COLLEGE All Employees other tha Dea of Faculty ad VP of Fiace ad Admiistratio Basic Term Life, Basic Accidetal Death & Dismembermet, Optioal Term Life, Optioal Depedet Term
More informationHelping you reduce your family s tax burden
The RBC Do m i i o Se c u r i t i e s Family Trust Helpig you reduce your family s tax burde Professioal Wealth Maagemet Sice 1901 1 RBC Domiio Securities Charitable Gift Program Who should cosider a RBC
More informationguaranteed universal life
guarateed uiversal life Uited of Omaha Life Isurace Compay A Mutual of Omaha Compay product guide L8416_0314 For Producer use oly. Not for use with the geeral public. 1 Guaratee your cliets future. Guarateed
More informationT4032-ON, Payroll Deductions Tables CPP, EI, and income tax deductions Ontario Effective January 1, 2016
T4032-ON, Payroll Deductios Tables CPP, EI, ad icome tax deductios Otario Effective Jauary 1, 2016 T4032-ON What s ew as of Jauary 1, 2016 The major chages made to this guide sice the last editio are outlied.
More informationSTRAND: FINANCE. Unit 3 Loans and Mortgages TEXT. Contents. Section. 3.1 Annual Percentage Rate (APR) 3.2 APR for Repayment of Loans
CMM Subject Support Strad: FINANCE Uit 3 Loas ad Mortgages: Text m e p STRAND: FINANCE Uit 3 Loas ad Mortgages TEXT Cotets Sectio 3.1 Aual Percetage Rate (APR) 3.2 APR for Repaymet of Loas 3.3 Credit Purchases
More informationThe Time Value of Money in Financial Management
The Time Value of Moey i Fiacial Maagemet Muteau Irea Ovidius Uiversity of Costata irea.muteau@yahoo.com Bacula Mariaa Traia Theoretical High School, Costata baculamariaa@yahoo.com Abstract The Time Value
More informationSubject CT1 Financial Mathematics Core Technical Syllabus
Subject CT1 Fiacial Mathematics Core Techical Syllabus for the 2018 exams 1 Jue 2017 Subject CT1 Fiacial Mathematics Core Techical Aim The aim of the Fiacial Mathematics subject is to provide a groudig
More informationAccumUL Plus. United of Omaha Life Insurance Company A Mutual of Omaha Company. product guide
Uited of Omaha Life Isurace Compay A Mutual of Omaha Compay AccumUL Plus product guide L7864_1211 Product base pla features, provisios ad riders may ot be approved i all states. For producer use oly. Not
More informationT4032-BC, Payroll Deductions Tables CPP, EI, and income tax deductions British Columbia Effective January 1, 2016
T4032-BC, Payroll Deductios Tables CPP, EI, ad icome tax deductios British Columbia Effective Jauary 1, 2016 T4032-BC What s ew as of Jauary 1, 2016 The major chages made to this guide, sice the last editio,
More informationSummary of Benefits. Management Consulting & Research, LLC
Summary of Beefits Maagemet Cosultig & Research, LLC All MCR Full Time Employees ad all other Full Time Employees Basic Term Life, Basic Accidetal Death & Dismembermet, Optioal Term Life, Optioal Depedet
More informationPublished financial statements of limited companies
3 Published fiacial statemets of limited compaies this chapter covers... I this chapter we focus o the published fiacial statemets of limited compaies ad look at: the purpose ad compoets of fiacial statemets
More informationfor a secure Retirement Foundation Gold (ICC11 IDX3)* *Form number and availability may vary by state.
for a secure Retiremet Foudatio Gold (ICC11 IDX3)* *Form umber ad availability may vary by state. Where Will Your Retiremet Dollars Take You? RETIREMENT PROTECTION ASSURING YOUR LIFESTYLE As Americas,
More informationYour guide to Protection Trusts
Your guide to Protectio Trusts Protectio Makig the most of your Aviva protectio policy Nobodylikestothikaboutwhatwill happewhetheyhavegoe.you realready thikigaheadbyhavigaprotectiopolicy iplace,whichcouldhelptheoesyoulove
More informationMethodology on setting the booking prices Project Development and expansion of Bulgartransgaz EAD gas transmission system
Methodology o settig the bookig prices Project Developmet ad expasio of Bulgartrasgaz EAD gas trasmissio system Art.1. The preset Methodology determies the coditios, order, major requiremets ad model of
More informationT4032-MB, Payroll Deductions Tables CPP, EI, and income tax deductions Manitoba Effective January 1, 2016
T4032-MB, Payroll Deductios Tables CPP, EI, ad icome tax deductios Maitoba Effective Jauary 1, 2016 T4032-MB What s ew as of Jauary 1, 2016 The major chages made to this guide sice the last editio are
More informationCurrent Year Income Assessment Form 2017/18
Curret Year Icome Assessmet Form 2017/18 Persoal details Your Customer Referece Number Your Customer Referece Number Name Name Date of birth Address / / Date of birth / / Address Postcode Postcode If you
More informationSummary of Benefits RRD
Summary of Beefits RRD All Eligible Employees Basic Term Life, Optioal Term Life, Optioal Depedet Term Life ad Optioal Accidetal Death & Dismembermet Issued by The Prudetial Isurace Compay of America Effective:
More informationguaranteed universal life express (gule)
guarateed uiversal life express (gule) Guaratee tomorrow. Focus o today. Uited of Omaha Life Isurace Compay A Mutual of Omaha Compay product guide L7464_0314 For Producer use oly. Not for use with the
More informationSummary of Benefits THE SCRIPPS RESEARCH INSTITUTE
Summary of Beefits THE SCRIPPS RESEARCH INSTITUTE All Active Full Time Beefit Eligible Employees Workig i Califoria Basic Term Life, Basic Accidetal Death & Dismembermet, Buy-Up Term Life, Buy-Up Depedet
More informationAPPLICATION FORM. Janus Henderson Investors. Valid from 30 May SECTION 1 About yourself
Jaus Hederso Ivestors APPLICATION FORM Valid from 30 May 2017 You should use this form if you wish to ivest i the Hederso Ivestmet Fuds Limited rage. Further iformatio is cotaied i the Prospectus, the
More informationKEY INFORMATION DOCUMENT CFD s Generic
KEY INFORMATION DOCUMENT CFD s Geeric KEY INFORMATION DOCUMENT - CFDs Geeric Purpose This documet provides you with key iformatio about this ivestmet product. It is ot marketig material ad it does ot costitute
More informationAccelerated Access Solution. Chronic Illness Living Benefit (California Only) Access your death benefits while living.
Chroic Illess Livig Beefit (Califoria Oly) Access your death beefits while livig. Accelerated Access Solutio Chroic Illess Accelerated Death Beefit Rider (optioal) for Secure Lifetime GUL 3; Value+ Protector
More informationApEx10. Overseeing on a day-to-day basis safeguarding and administering investments or holding of client money
ApEx10 Overseeig o a day-to-day basis safeguardig ad admiisterig ivestmets or holdig of cliet moey Summary of Learig Outcomes ApEx10 OVERSEEING ON A DAY TO DAY BASIS SAFEGUARDNG AND ADMINISTERING INVESTMENTS
More informationLegalSpotlight Protecting Your Interests: Taking and Enforcing Security in Ontario
LegalSpotlight Protectig Your Iterests: Takig ad Eforcig Security i Otario Jim s factory i Toroto sells maufacturig equipmet to a customer uable to pay the etire purchase price o delivery. How ca he secure
More informationReview Procedures and Reporting by Peer Reviewer
Review Procedures ad Reportig by Peer Reviewer QUALITY OF REPORTING BY AUDITORS Desired Quality Audit report to cotai a clear writte expressio of opiio o the fiacial iformatio PU should have policies ad
More informationFirst determine the payments under the payment system
Corporate Fiace February 5, 2008 Problem Set # -- ANSWERS Klick. You wi a judgmet agaist a defedat worth $20,000,000. Uder state law, the defedat has the right to pay such a judgmet out over a 20 year
More information43. A 000 par value 5-year bod with 8.0% semiaual coupos was bought to yield 7.5% covertible semiaually. Determie the amout of premium amortized i the 6 th coupo paymet. (A).00 (B).08 (C).5 (D).5 (E).34
More informationTUSCULUM COLLEGE. Group Number:
The Guardia Life Isurace Compay of America, New York, NY 10004 Group Number: 00498351 TUSCULUM COLLEGE Here you'll fid iformatio about your followig employee beefit(s). Be sure to review the eclosed -
More informationUS Dollar Bank Account
FACT SHEET Page 1 of 3 Please keep for future referece US Dollar Bak Accout Call us o 0800 092 3300 Fact Sheet (icludig Fiacial Services Compesatio Scheme (FSCS) Iformatio Sheet & Exclusios List) The US
More informationFINANCIAL MATHEMATICS
CHAPTER 7 FINANCIAL MATHEMATICS Page Cotets 7.1 Compoud Value 116 7.2 Compoud Value of a Auity 117 7.3 Sikig Fuds 118 7.4 Preset Value 121 7.5 Preset Value of a Auity 121 7.6 Term Loas ad Amortizatio 122
More informationAccelerated Access Solution. Chronic Illness Protection Rider. Access your death benefits while living.
Chroic Illess Protectio Rider Access your death beefits while livig. Accelerated Access Solutio Optioal Livig Beefit Rider for Secure Lifetime GUL 3; Value+ Protector ; Max Accumulator+ Policies issued
More informationYour Appeal Rights Under the Income Tax Act
Your Appeal Rights Uder the Icome Tax Act P148(E) Rev. 00 3327 Visually impaired persos ca get iformatio o services available to them, ad ca order publicatios i braille or large prit, or o audio cassette
More information0.07. i PV Qa Q Q i n. Chapter 3, Section 2
Chapter 3, Sectio 2 1. (S13HW) Calculate the preset value for a auity that pays 500 at the ed of each year for 20 years. You are give that the aual iterest rate is 7%. 20 1 v 1 1.07 PV Qa Q 500 5297.01
More informationEnhancing Service to Large Businesses. The Audit Protocol Real-Time Audit Concurrent Audit Single-Window Focus
Ehacig Service to Large Busiesses The Audit Protocol Real-Time Audit Cocurret Audit Sigle-Widow Focus 5&(5HY Visually impaired persos ca get iformatio o services available to them, ad ca order publicatios
More informationSummary of Benefits WESTERN MISSOURI MEDICAL CENTER
Summary of Beefits WESTERN MISSOURI MEDICAL CENTER All Full Time Maagemet ad Physicias other tha Executives Basic Term Life, Basic Accidetal Death & Dismembermet, Optioal Term Life, Optioal Depedet Term
More informationAppendix 1 to Chapter 5
Appedix 1 to Chapter 5 Models of Asset Pricig I Chapter 4, we saw that the retur o a asset (such as a bod) measures how much we gai from holdig that asset. Whe we make a decisio to buy a asset, we are
More informationChapter Four 1/15/2018. Learning Objectives. The Meaning of Interest Rates Future Value, Present Value, and Interest Rates Chapter 4, Part 1.
Chapter Four The Meaig of Iterest Rates Future Value, Preset Value, ad Iterest Rates Chapter 4, Part 1 Preview Develop uderstadig of exactly what the phrase iterest rates meas. I this chapter, we see that
More information1 Savings Plans and Investments
4C Lesso Usig ad Uderstadig Mathematics 6 1 Savigs las ad Ivestmets 1.1 The Savigs la Formula Lets put a $100 ito a accout at the ed of the moth. At the ed of the moth for 5 more moths, you deposit $100
More informationBroker Partnerships and Protocols
Broker Parterships ad Protocols As our broker parter, you are a importat ally i promotig ad sellig FM Global, a leadig worldwide provider of commercial property isurace. As a basis for placig philosophically
More informationLife Products Bulletin
Life Products Bulleti Tredsetter Super Series Tredsetter Super Series: 2009 Chages Effective September 1, 2009, Trasamerica Life Isurace Compay is releasig ew rates for Tredsetter Super Series level premium
More informationof Asset Pricing R e = expected return
Appedix 1 to Chapter 5 Models of Asset Pricig EXPECTED RETURN I Chapter 4, we saw that the retur o a asset (such as a bod) measures how much we gai from holdig that asset. Whe we make a decisio to buy
More informationModels of Asset Pricing
APPENDIX 1 TO CHAPTER 4 Models of Asset Pricig I this appedix, we first examie why diversificatio, the holdig of may risky assets i a portfolio, reduces the overall risk a ivestor faces. The we will see
More informationModels of Asset Pricing
APPENDIX 1 TO CHAPTER4 Models of Asset Pricig I this appedix, we first examie why diversificatio, the holdig of may risky assets i a portfolio, reduces the overall risk a ivestor faces. The we will see
More informationChapter Four Learning Objectives Valuing Monetary Payments Now and in the Future
Chapter Four Future Value, Preset Value, ad Iterest Rates Chapter 4 Learig Objectives Develop a uderstadig of 1. Time ad the value of paymets 2. Preset value versus future value 3. Nomial versus real iterest
More informationPensions Legal Update
Issue 127 Jauary 2008 Pesios Legal Update Reproduced with the kid permissio of PLC Magazie Pesios Bill. The Pesios Bill has bee published. P.1 Scheme rules: draftig errors. The High Court has rejected
More informationA guide for members RPS 65
A guide for members RPS 65 Disclaimer The iformatio provided i this guide is iteded for geeral iformatio ad illustrative purposes. Your beefits will be worked out i accordace with ad subject to the goverig
More informationAccelerated Access Solution. Chronic Illness Protection Rider. Access your death benefits while living.
Chroic Illess Protectio Rider Access your death beefits while livig. Accelerated Access Solutio Optioal Livig Beefit Rider for Secure Lifetime GUL 3; Value+ Protector ; Max Accumulator+ Policies issued
More informationREITInsight. In this month s REIT Insight:
REITIsight Newsletter March 2014 REIT Isight is a mothly market commetary by Resource Real Estate's Global Portfolio Maager, Scott Crowe. It discusses our perspectives o major evets ad treds i real estate
More informationHighIncome FUND. Offering Advisor Series Units and Series F Units of the Fund in each of the provinces and territories of Canada.
2015 HighIcome November 12, 2015 Offerig Advisor Series Uits ad Series F Uits of the Fud i each of the provices ad territories of Caada. This Offerig Memoradum costitutes a offerig of the securities described
More informationof Asset Pricing APPENDIX 1 TO CHAPTER EXPECTED RETURN APPLICATION Expected Return
APPENDIX 1 TO CHAPTER 5 Models of Asset Pricig I Chapter 4, we saw that the retur o a asset (such as a bod) measures how much we gai from holdig that asset. Whe we make a decisio to buy a asset, we are
More informationBUSINESS PLAN IMMUNE TO RISKY SITUATIONS
BUSINESS PLAN IMMUNE TO RISKY SITUATIONS JOANNA STARCZEWSKA, ADVISORY BUSINESS SOLUTIONS MANAGER RISK CENTER OF EXCELLENCE EMEA/AP ATHENS, 13TH OF MARCH 2015 FINANCE CHALLENGES OF MANY FINANCIAL DEPARTMENTS
More informationCAF 12 MONTH FIXED RATE SAVER Business, Charity and Trust Savings Terms and Conditions Effective from 25 May 2018
CAF 12 MONTH FIXED RATE SAVER Busiess, Charity ad Trust Savigs Terms ad Coditios Effective from 25 May 2018 workig i associatio with The followig Terms ad Coditios cover busiess, charity ad trust savigs
More informationIII. RESEARCH METHODS. Riau Province becomes the main area in this research on the role of pulp
III. RESEARCH METHODS 3.1 Research Locatio Riau Provice becomes the mai area i this research o the role of pulp ad paper idustry. The decisio o Riau Provice was supported by several facts: 1. The largest
More informationSection 3.3 Exercises Part A Simplify the following. 1. (3m 2 ) 5 2. x 7 x 11
123 Sectio 3.3 Exercises Part A Simplify the followig. 1. (3m 2 ) 5 2. x 7 x 11 3. f 12 4. t 8 t 5 f 5 5. 3-4 6. 3x 7 4x 7. 3z 5 12z 3 8. 17 0 9. (g 8 ) -2 10. 14d 3 21d 7 11. (2m 2 5 g 8 ) 7 12. 5x 2
More informationRollover & Superannuation Fund
Rollover & Superauatio Fud A fud that allows you to build your savigs for retiremet i a tax effective eviromet. Product Disclosure Statemet This is a combied Fiacial Services Guide ad Product Disclosure
More informationTerms and conditions. Santander Sharedealing. A. General conditions TERMS AND CONDITIONS
TERMS AND CONDITIONS Terms ad coditios Satader Sharedealig A. Geeral coditios 1 Itroductio 1.1 Abbey Stockbrokers Limited tradig as Satader Sharedealig ( SSD ) provides a executio-oly sharedealig service
More informationPPI Investment Advice
Tailored property advice ad solutios PPI Ivestmet Advice www.ppiivestmetadvice.com.au portfoliopropertyivestmets.com.au/propertycoach AFSL umber 276 895 PPI, chagig the property ivestig ladscape! Everythig
More informationBenefits as Part of Compensation. Professional Development Series September 11, 2017 Elizabeth G. Levitzky, MBA, PhD
Beefits as Part of Compesatio Professioal Developmet Series September 11, 2017 Elizabeth G. Levitzky, MBA, PhD Employer Paid Beefits Cost the employer approximately 35-40% of aual compesatio Shared Costs
More information2009 Physician Hospital Valuation Survey
2009 Physicia Hospital Valuatio Survey How do physicia hospital compaies assess value? i cooperatio with We are pleased to aouce the results of the 2009 Physicia Hospital Valuatio Survey. I cooperatio
More informationDefined Benefit Section. Member Booklet. Your Pension. Your Future.
Defied Beefit Sectio Member Booklet Your Pesio. Your Future. 2 Cotets Itroductio 2 The DB Sectio of the Scheme at a glace 3 Your beefits at Normal Retiremet Date 4 Death before retiremet 6 Death after
More informationModels of Asset Pricing
4 Appedix 1 to Chapter Models of Asset Pricig I this appedix, we first examie why diversificatio, the holdig of may risky assets i a portfolio, reduces the overall risk a ivestor faces. The we will see
More informationMafatlal Centre, 10th Floor, Nariman Point, Mumbai CIN: U65991MH1996PTC Tel.: Fax:
Mafatlal Cetre, 10th Floor, Narima Poit, Mumbai - 400 021 CIN: U65991MH1996PTC100444 Tel.: 91-22 66578000 Fax: 91-22 66578181 www.dspblackrock.com Jauary 8, 2018 Dear Uit Holder, Sub: Chage i Fudametal
More informationAgent product guide. Advantage Builder II. Indexed Universal Life /09
Aget product guide Advatage Builder II Idexed Uiversal Life 16480 1/09 Advatage Builder II Idexed Uiversal Life is a flexible premium uiversal life isurace policy with a idex-liked iterest creditig feature.
More informationIntroduction to Financial Derivatives
550.444 Itroductio to Fiacial Derivatives Determiig Prices for Forwards ad Futures Week of October 1, 01 Where we are Last week: Itroductio to Iterest Rates, Future Value, Preset Value ad FRAs (Chapter
More informationBaan Project Project Invoicing
Baa Project Module Procedure UP061A US Documetiformatio Documet Documet code : UP061A US Documet group : User Documetatio Documet title : Applicatio/Package : Baa Project Editio : A Date : July 1998 Copyright
More informationBaan Finance Accounts Receivable
Baa Fiace Accouts Receivable Module Procedure UP036A US Documetiformatio Documet Documet code : UP036A US Documet group : User Documetatio Documet title : Accouts Receivable Applicatio/Package : Baa Fiace
More informationChapter 4: Time Value of Money
FIN 301 Class Notes Chapter 4: Time Value of Moey The cocept of Time Value of Moey: A amout of moey received today is worth more tha the same dollar value received a year from ow. Why? Do you prefer a
More informationSQN SECURED INCOME FUND PLC (Registered number ) HALF-YEARLY REPORT AND UNAUDITED CONDENSED FINANCIAL STATEMENTS
SQN SECURED INCOME FUND PLC (Registered umber 09682883) HALF-YEARLY REPORT AND UNAUDITED CONDENSED FINANCIAL STATEMENTS For the six moths eded 31 December 2017 CONTENTS Page Strategic Report Highlights
More informationCompanies COMPANIES BUILDING ON A SOLID FOUNDATION. 1 Intrust Manx
Compaies COMPANIES BUILDING ON A SOLID FOUNDATION 1 Itrust Max Itrust Max Limited Itrust (Max) Limited is based i Douglas, Isle of Ma. Our objective is to provide a bespoke, flexible, cost-effective, efficiet
More informationChapter 3. Compound interest
Chapter 3 Compoud iterest 1 Simple iterest ad compoud amout formula Formula for compoud amout iterest is: S P ( 1 Where : S: the amout at compoud iterest P: the pricipal i: the rate per coversio period
More informationProspectus Directive Regulation (EC/809/2004), as amended.
Prospectus Directive Regulatio (EC/809/2004), as ameded. Disclaimer This briefig ote has bee prepared as a referece tool to illustrate the chages to Prospectus Directive Regulatio EC 809/2004 1, as ameded
More informationFact Sheet including Terms & Conditions (including Financial Services Compensation Scheme (FSCS) Information Sheet & Exclusions List) Summary Box
FACT SHEET Page 1 of 5 Please keep for future referece Call us o 0800 092 3300 Term Deposit Fact Sheet icludig Terms & Coditios (icludig Fiacial Services Compesatio Scheme (FSCS) Iformatio Sheet & Exclusios
More informationSTAFF EXPLANATORY BOOKLET
STAFF EXPLANATORY BOOKLET July 2015 Cotets Page Welcome to the Staff Sectio of the AA Pesio Scheme 3 What is it? 4 Ca I joi? What do I pay? 4 What do I get? 5 What about icreases? 8 Is my family protected?
More information