SECURITIZATION - LUX.

Email to client (Ref. Tel. & Email w/ Remko): I have discussed with our cooperation partner a Sharia-Equity-Tracker solution on Trisyntec LLC, which would hold further interests in the “Devices” corporation and the “AI” corporation. This is not an AMC, which would require licensing, but a note on a holding company, which would also require an annual valuation from an acceptable valuation provider. We have been informed that they can implement such a solution without capital calls, but some elements would require some preparatory work from you.

There would be additional costs associated with a required placement memorandum of indicative USD 10,000 and unknown costs of the Shariah board to review and approve the note.

You will need to check with the Shariah board whether the note needs to hold the shares directly (true sales) or if a performance agreement (synthetic) between the Luxembourg compartment and Trisyntec LLC is acceptable. Furthermore,…

Question: "considering the nature of AMC, can US investor invest into xxx? Would the fact, that US investor has account in Switzerland change anything?" Remko / 12.9.2023: "The US investors are a bit of a pickle. The product is not really for US investors. Should it be a large institutional client it is a different story. "

Feedback Stephan (AAFS) on an AMC case / 04.09.2023

"Fiscal treatment is always tricky to comment on, as we are not allowed to provide tax advise (several laws are clearly stating, that this can only be done by qualified and registered tax advisors) but a general comment by myself:

The tax treatment depends on the status of the investor.

If the investor is a pension fund, a foundation, or any other non-taxable, tax-exempt or tax-reduced investor the tax treatment should be similar to any other bonds investment issued by a corporate.

Same applies to any physical Person, investing into securities, eg corporate bonds.

Depending on their individual tax treatment, realised gains and losses might be taxed according to their tax situation, as well as the duration of their holding.

The client can avoid custody and brokerage fees by registering the securitzation vehicle (compartment) and placing orders via the fund administrator. In this case, the client invests in various sub-classes of his hedge fund.

Remko returned to RP that they can settle it with a fixed fee when the client uses a registered structure.

"The fee will be 500 USD per trade and that’s it. So the 6 bps will be 500 USD fixed. These subscriptions and redemptions are always a lot of work from a process point of view. "