Inverworld, Inc., et al. - Page 144

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                  LTD paid INC to maintain investments placed in the Currency                             
            Fund.  LTD charged its clients a 3-percent placement cost plus an                             
            annual management fee, starting with the second year, of 1.00                                 
            percent of the value of the assets under management.                                          
            Accordingly, the arm’s length charge for INC’s services for that                              
            operation is the amount of clients’ newly placed net assets times                             
            3 percent plus the amount of clients’ already placed net assets                               
            times 1.00 percent.                                                                           
                  LTD paid INC to maintain investments placed in the FEIM                                 
            Fund.  LTD charged its clients a placement cost based on a                                    
            sliding scale of 4.00 percent to 0.25 percent, depending upon the                             
            amount of the investment.  LTD also charged an annual management                              
            fee, starting with the second year, of 1.00 percent of the value                              
            of the assets under management.  Petitioners did not present                                  
            evidence on and the record does not reveal the precise amounts of                             
            clients’ funds at each level of the graduated placement costs.                                
            Consequently, we are unable to calculate LTD’s FEIM Fund                                      
            commission on a sliding scale.  We note that Deloitte used in its                             
            audit a figure of 3.00 percent, and we apply that amount in the                               
            instant case.  Accordingly, the arm’s length charge for INC’s                                 
            services for that operation is the amount of clients’ newly                                   
            placed net assets times 3.00 percent plus the amount of clients’                              
            already placed net assets times 1.00 percent.                                                 
                  LTD paid INC to maintain investments placed in the Inversat                             
            Fund.  LTD charged its clients a placement cost based on a                                    
            sliding scale of 3.50 percent to 0.25 percent, depending upon the                             




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