Noster Capital — Tax Jurisdictions
Noster Capital International is incorporated in the Cayman Islands — a tax jurisdiction in which a multitude of investment firms are domiciled. This is a long standing, accepted and conventional practice in the investment industry.
Mr. O'Neill is not and has never been a shareholder of Noster Capital International but is, instead, a member of Noster Capital LLC - a limited liability company registered in Delaware but carrying on business in New York. This is the sole entity from which Mr. O'Neill is remunerated for his services. This is conventional practice for US citizens and residents and is completely in compliance with the above referenced tax jurisdictions for which Mr. O'Neill has tax responsibility.
Limited liability companies are what is known as "pass-through entities" and, as such, do not pay tax at the entity level. Entity income is reported by the members and taxed as ordinary income in accordance with the member´s local tax residency, which in the case of Mr. O'Neill is New York City — one of the highest taxing jurisdictions in the United States.
Noster Capital — Restrictions
In light of the pending marriage between H.R.H. Princess Madeleine of Sweden and Mr. O'Neill, he will voluntarily restrict himself from any investments carried out by Noster Capital that involve a Swedish concern. Specifically, he will not be involved in any investment that relates to:
An entity that is listed on the Stockholm bourse; or
An entity that derives a significant portion (greater than 1/3) of total group revenues from Swedish sources.