- 222 - 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 Inversat 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 such 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 Matric Fund. LTD charged its client, Matric Corp., a consulting fee of $47,500 to maintain the Matric Fund. Accordingly, the arm’s length charge for INC’s services for that operation is $47,500. LTD paid INC to maintain investments placed in TVA. LTD charged its client, TVA, Inc., an administration fee of $5,000 per month. Accordingly, the arm’s length charge for INC’s services for that operation is $5,000 per month. LTD paid INC to effect currency transactions. The amount that LTD earned is the amount that LTD charged its clients. Some of LTD’s income, however, was generated by LTD’s Guadalajara office and not by INC. Consequently, INC will not be allocated that income. Accordingly, the arm’s length charge for INC’sPage: Previous 212 213 214 215 216 217 218 219 220 221 222 223 224 225 226 227 228 229 230 231 Next
Last modified: May 25, 2011