- 221 - 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 thePage: Previous 211 212 213 214 215 216 217 218 219 220 221 222 223 224 225 226 227 228 229 230 Next
Last modified: May 25, 2011