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								SingeLLCOpAgreement/grantToMembers.md
									
									
									
									
									
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								SingeLLCOpAgreement/grantToMembers.md
									
									
									
									
									
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|  | # Grant Of Profit Interests To Members (capitalization table) | ||||||
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|  | 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. | ||||||
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|  | 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. | ||||||
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|  | In consideration of Members providing services for the benefit of the Company, the Company hereby issues to Members the percentage interests below: | ||||||
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|  | *  | ||||||
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|  | *  | ||||||
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|  | *  | ||||||
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|  | The above three interests are fully vested.  | ||||||
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|  | * Reserved for future members pre SEAL capital raise :  | ||||||
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|  | * Reserved for SEAL raise :  | ||||||
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|  | The above two interests are subject to negoiation in regards to vesting. | ||||||
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|  | (above is conitional and not refelcting current cap table, will be changed before sending for signig) | ||||||
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