- 3 -
On November 18, 1999, each of the flowthrough entities
purportedly entered into two option trades involving
Euros with AIG International, Inc. (AIG). One of those option
trades was the purported purchase from AIG on November 18, 1999,
of an option for a stated volume of Euros, which petitioners
refer to as the purchased Euro option. The second option trade
was the sale to AIG on the same date of an option for essentially
the same volume of Euros but at a different so-called strike or
exercise price, which petitioners refer to as the sold Euro
option. The two option trades with AIG into which petitioners’
respective flowthrough entities purportedly entered on November
18, 1999, may be summarized as follows:
Payoff Amount
(U.S. $
Option Premium Equivalent) Strike Price
Long Position $26,700,190 $548,240,768 1.0535
Short Position $26,433,172 $548,761,167 1.0545
(For convenience, we shall sometimes refer collectively to the
purported purchased Euro option and the purported sold Euro
option as the Euro options.)
On November 30, 1999, petitioners’ respective flowthrough
entities purportedly contributed their respective Euro options
and $667,500 in cash to Evergreen Trading in exchange for
slightly less than a one-third member or partner interest
therein.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: November 10, 2007