Welcome to the Structured Ownership Program (S.O.P.)
Unlock powerful tax efficiency and investment opportunities through our exclusive Structured Ownership Program. Designed for high-net-worth individuals and sophisticated investors, this program leverages a strategic LLC structure to generate substantial tax offsets and potential investment returns.
Take control of your tax strategy while participating in institutional-grade investing. Learn how our Structured Ownership Program can work for you.
This restricted-access opportunity uses a specially designed Limited Liability Company to leverage capital contributions into a negative K-1 up to ten times larger than the initial contribution. Due to the unique design of the LLC operations, and the effect of special allocations under the tax code, this negative K-1 can be used to offset both ordinary income and long term capital gains. For more detailed information, please schedule a personal consultation.
- Ownership Structure: You, the client, retain 99% ownership of a New Series LLC, with the Master LLC managing the remaining 1%.
- Capital Contribution: Begin by making a capital contribution to the New Series LLC.
- Strategic Leverage: The LLC obtains a third-party loan (15-year interest-only with a 15.5-year balloon), typically 7–9 times your contribution. This loan creates a Debt Restoration Obligation (DRO), boosting your basis for enhanced tax planning.
- Active Investing: The Series LLC engages in active, high-volume trading strategies such as foreign currency exchange and factoring, in compliance with IRS codes §§469(c) and 1092(d).
- Loss Allocation: Thanks to IRC §704(b), profits are allocated to the Master LLC, while losses—often 8–10 times your capital contribution—are passed to you via a K-1.
- Offset Income: These non-passive losses can be used to offset both ordinary income and long-term capital gains, potentially generating K-1s of -$800K to -$1M.
- Enjoy a 3–7% net annual return on your capital contribution.
- A 3.5% administrative fee is applied to your generated K-1.
- Ordinary Income: $100K contribution + $28K fee could yield a K-1 of -$800K.
- Capital Gains: $100K contribution + $35K fee could yield a K-1 of -$1M.