USA HeadquartersAntenna in RussiaAntenna in Luxembourg IBC GROUPIBC GROUPIBC GROUP MiamiTowerLyteiny pr Ave. Charles de Gaulle 100 S.E. 2nd Street, Suite 2222 ASt.Petersburg, Luxembourg, L-1653 Miami, FL, USARussia Tel: +1 (305) Tel:+7 (911) Tel: Fax: +1 (305) Fax:+7 (812) Fax:

IBC’s Executive Summary 26 years of experience in secure investments 185 consultants in wide range of jurisdictions, including tax havens Specializes in supporting clients to successfully acquire, manage and sell secure investments (real estate and gold) while minimizing taxes.

Very low tax rates (Constitution prohibits personal income tax) State government budget is almost balanced Continuing vigorous population growth (2-3% per year) Tourism:84,000,000 visitors annually Healthy Business Climate: few regulations, little bureaucracy & “right to work” law (few unions). Very pro-international climate, dynamic economy Agriculture: 1 st citrus state, 2 nd cattle state Banking and finance: 3 rd largest US Center Mining: $1.92 Bln/year industrial mineral production, fifth in the USA Trade: 5 deep water ports & 40+ free trade zones High profile and well-educated population; many Europeans, wealthier classes Main real estate trend: immigration of wealthy investors Now – highly discounted prices (substantial capital gain opportunities) FLORIDA

NEW YORK Very high tax rates in New York State and New York City NYS & NYC budgets suffering severe deficits ($40 bln. & 25 bln.) Population is steadily declining Strained business climate (tough bureaucracy, many regulations & strong unions) Older industries declining (“rust belt”, textile & small manufacturers) Still № 1 in banking and finances, but hemorrhaging Tourism is growing industry but still lukewarm (approx. 60 mm) International trade (still active but declining; only 20± trade zones) Population composition problems (high poverty rates, large welfare classes, emigration of wealthier classes) Main real estate trends: lower growth and out migration Lower potential for real estate gains

Growth & price statistics Single Home price index Source: US Bureau of Economic Analysis, Standard & Poor's Case-Shiller Home Price Indices FL +81%NY + 2% :

Example № 1: Russian purchase of condominium in the USA Mr. Ivanov, a Russian citizen and tax resident. Mr. Ivanov purchases a condominium for $250,000 and spends a further $50,000 to renovate the property. Mr. Ivanov rents out his condominium at the normal rate of 12% a year, equal to $36,000 gross income per year. Mr. Ivanov takes no property tax exemptions and purchased the condominium unit with fee simple title in his own name. He derives no other income from the US. What are the tax consequences in New York and Florida?

Comparison of Rental Taxes - New York City vs. Florida New York, New YorkMiami, Florida Purchase Price + Improvements 300,000 Gross rent income (est.) $3,000 per month 36,000 Renting commissions (8.334%) (3,000) Less – Maintenance ($1,000/mo) (12,000) Less – Depreciation (3.39%)(10,170) Net rent income subject to taxes. $10,830 NY State Income Tax (4,5%) $487ZERO NY City Income tax (2,9%)$302ZERO Federal tax (15%)$1,625 - Housing in Miami is on average 66% cheaper than a comparable sq. ft sized property in NYC. - Profits from rents in NYC are subject to federal, state that the and city income tax at local rates. - For the same purchase price the Miami condo would be substantially larger. - Depreciation is a notional amount for tax purposes.

Example № 2. Sale of United States Condominium by Russian owner. Now assume that Mr. Ivanov, after holding his apartment, for five years, finds a buyer. The real estate market has recovered and he is able to sell the property (seller’s closing costs included) for $500,000. What are the comparative tax consequences to Mr. Ivanov in New York City and Miami ?

Sale of Property – Approximate Tax Consequences New York City vs. Miami, Florida New York, New YorkMiami, Florida Basis on Purchase250,000 Improvements50,000 Depreciation Recapture(50,850) Total Adjusted Basis249,150 Sale Price 500, Selling Commissions (6%) (30,000) Closing Costs (est. 1.5%) (7,500) Net gain on Sale 213,350 US federal tax on Gain (20%) (42,670) NY city income tax (3,648%) (7,783)ZERO NY State income tax (6,85%) (14,614)ZERO New York City Transfer Tax (1.425% of sale price) (7,125)ZERO New York State Transfer Tax ($4/1,000 sale price) (2,000)ZERO TOTAL TAX ON SALE 66,40942,670