Dear SBA,

I have been thinking about how to create a Tax Free Income Fund and I
would like some feed-back.

By creating an  Early Stage Venture Capital Limited Partnership
(ESVCLP) offers the the possibility of matching funding from the
government and a significant tax breaks.  By combining high yielding
debt / preference shares can you 'wash' the tax liability?

Eg Theoretical Portfoilo

$10 Million total

$1 Million - into Startmate / YCombinator-type startups
$5 Million into high yield debt - over 20% pa
$2 Million into Credit Union preference shares - return up to 8% full
franked
$2 Million into unlisted mining companies


Expected value of the portfolio  $10 Million

Web startups: Zero or ($10 Million if we win the lottery)
High Yield debt: $7 Million
Credit Union Shares: $2 Million
Unlisted mining companies: $1 Million or ($30 Million if we win the
lottery again)

In Australia, Venture Capital as an asset-class destroys lots of
money.The track record is appalling.

>From AusIndustry website: "Fund managers seeking to raise a new
venture capital fund of at least $10 million and not more than $100
million for investing in Australian businesses may be eligible for
ESVCLP registration.

Registration entitles a fund to flow-through tax treatment and its
investors (whether resident or non-resident) receive a complete tax
exemption on their share of the fund's income (both revenue and
capital).

Australian businesses with assets of less than $50 million may be able
to access capital from funds registered under this program if their
primary activity is not finance or property development."

A quick summary  of the rules are no investment may exceed 20% of the
fund, ie minimum of 5 investments.  Every so often, the government
grants dollar for dollar matching of investments funds.  Minimum size
of fund $10 Million etc.

It takes about a year and about $100K to establish a ESVCLP.

The ESVCLP was never designed for Income funds and I know that
AusIndustry will whine but if I stay within the guideline I can create
an innovative funding vehicle for new ventures.


Any thoughts / comments?

Richard Hayes



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