diff --git a/SingeLLCOpAgreement/grantToMembers.md b/SingeLLCOpAgreement/grantToMembers.md new file mode 100644 index 0000000..52d684d --- /dev/null +++ b/SingeLLCOpAgreement/grantToMembers.md @@ -0,0 +1,30 @@ + +# Grant Of Profit Interests To Members (capitalization table) + +The Company desires to issue a percentage of the Company profits +designated as “Profits Interest Units” to the Member in connection with +Members performance of services for the benefit of the Company. + +The parties intend that the Profits Interest Units issued pursuant to this Agreement constitute “profits interests,” as described in Section 4.01 of Rev. Proc. 93-27, 1993-2 C.B. 343, as clarified by Rev. Proc. 2001-43, 2001-34 I.R.B. 191, issued by the Internal Revenue Service. + +The Company will revalue its assets as of the Effective Date in accordance with Treasury Regulations Section 1.704-1(b)(2)(iv)(f)(5)(iii) and the Capital Accounts of the Members of the Company will be adjusted to reflect such revaluation. + +In consideration of Members providing services for the benefit of the Company, the Company hereby issues to Members the percentage interests below: + + +* + +* + +* + +The above three interests are fully vested. + +* Reserved for future members pre SEAL capital raise : + +* Reserved for SEAL raise : + +The above two interests are subject to negoiation in regards to vesting. + + +(above is conitional and not refelcting current cap table, will be changed before sending for signig)