Lights! Cameras! Action!
To "jumpstart" Louisiana's film industry, the Louisiana Motion Picture Incentive Program was created in 2002 to provide transferable Louisiana income tax credits as an incentive for the production of motion pictures in the State. The transferable income tax credit is equal to 25% of the production's expenses incurred directly in Louisiana plus an additional credit of 10% of payroll for the employment of Louisiana residents. These tax credits are available to individuals, corporations, trusts and partnerships with Louisiana tax liabilities.

Stonehenge Capital Company is making tax credits from major film studio productions available to qualified Louisiana taxpayers at a discount to face value, providing significant savings on taxes, while helping to grow an exciting new Louisiana industry. Now is the time for you to take action!

Solid Experience.
Stonehenge Capital Company is a Louisiana-headquartered company with approximately $500 million of private capital under management. Other offices are located in Birmingham, Columbus, Denver, Milwaukee, New York and Tampa. Our lines of business include:

• Private Equity and Venture Capital Investing.
• Entertainment Finance, Including Louisiana Motion Picture Tax Credits.
• Community Development Investing.
• Tax Credit Finance.

Stonehenge is a national leader in structuring tax-aided transactions and offers more tax credit experience than any other Louisiana firm. We have successfully closed over $600 million in tax credit transactions, and no tax credit associated with any of these transactions has ever been recaptured.

The Credits are Rolling.
Stonehenge is working with major entertainment companies filming in Louisiana to make tax credits available to Louisiana taxpayers at a discount to their face value. Stonehenge's transaction is considered the "gold standard" in the marketplace and our transaction benefits include:

• Substantial state income tax savings realized through the use of film tax credits.
• Simple, streamlined, easy-to-complete documentation.
• Protection against tax credit recapture.
• The opportunity to assist in the growth of an important Louisiana industry.

Taxpayers are shielded from recapture through multiple levels of protection, including:

• An extensive credit certification process by the state.
• Legal rulings by the state confirming the transaction structure.
• An indemnity.

For more information, call 225.408.3000. Our Film Tax Credit Team is ready to assist you.



Q: What is the Louisiana Motion Picture Incentive Program?
A. The Louisiana Film Tax Credit Program was created in 2002 to encourage film and video production in Louisiana and related economic development benefits. The program authorizes transferable Louisiana income tax credits of 25% of a production's expenses incurred directly in Louisiana plus an additional credit of 10% of payroll for the employment of Louisiana residents. Typically, the production companies earning the tax credits do not have sufficient Louisiana tax liability to use the tax credits. Stonehenge acquires the tax credits from these production companies and makes the tax credits available to Louisiana taxpayers at a discount to face value.

Q: Louisiana motion picture tax credits seem to be available from a number of sources in Louisiana, why should I choose Stonehenge?
A: Stonehenge's structure is the "gold-plated" model in the marketplace for several reasons:

• Stonehenge's structure provides multiple layers of protection to the taxpayer;
• Stonehenge partners only with financially sound, credit-worthy major studios;
• Stonehenge is a national leader in structuring tax credit enhanced transaction and offers more tax credit experience than any other Louisiana firm; and
• Stonehenge has successfully closed over $600 million in tax credit transactions, and no tax credit associated with any of these transactions has ever been recaptured.

Q: Can the tax credits be recaptured (taken back) by Louisiana? A: Under certain circumstances, the tax credits can be recaptured by Louisiana. Stonehenge's structure protects against recapture through multiple layers of protection, including:

• Private Letter Ruling. Stonehenge secures a private letter ruling from the Louisiana Department of Revenue (LDR) that addresses the generation of the tax credits, the transfer and allocation of the tax credits, the application of the tax credits, and the post-tax credit certification remedies of Louisiana.
• Multi-Party Certification Agreement. Stonehenge, the Louisiana Department of Economic Development (LED), the Governor's Office of Film and Television Development (Film Office), and the company producing the motion picture enter into a multi-party certification agreement, pursuant to which the parties agree on (i) the procedures by which LED and the Film Office will certify the amount of tax credits earned by the studio and the amount of tax credits that are no longer subject to recapture and (ii) limiting the post-certification remedies of LED and the Film Office.
• Louisiana Attorney General's Opinion. The Louisiana Attorney General has issued an opinion stating that LED may agree to only pursue actions against the person that commits fraud or makes a material misrepresentation in the tax credit certification process, and not the taxpayers.
• Recapture Guaranty. Stonehenge provides a recapture guaranty to the taxpayers.

Stonehenge's "belt-and-suspenders" approach to recapture is unmatched in the marketplace. Q: What if the motion picture is a bust?
A: The tax credits are not affected by the motion picture's success or failure. Moreover, the taxpayer is not required to make an investment in the motion picture in order to receive or use the tax credits. Therefore, the taxpayer has no ownership in the motion picture, and is not exposed to any risk if the motion picture ultimately fails in the marketplace.

Q: Is Stonehenge "putting its money where its mouth is"?
A: Yes. Stonehenge uses its own funds to acquire the tax credits and then makes the tax credits available to taxpayers. Contrast this structure to "brokering" the tax credits (i.e. serving as a "matchmaker") where the broker has no personal financial risk. Stonehenge's acquisition of the tax credits with our own funds is a multi-million dollar "vote of confidence" in our structure, and in the studios with which we partner.

Q: When do I have to pay Stonehenge for the tax credits?
A: Under Stonehenge's structure, taxpayers are not required to pay for tax credits until they have been certified by Louisiana. Typically, a taxpayer will pay Stonehenge shortly before a Louisiana tax payment is due, thereby generating an immediate tax savings when the tax credits are used.

Q: How much will I save on my state taxes?
A: Savings will vary from taxpayer to taxpayer, but a taxpayer should save about 10% on its state income taxes as a result of using the tax credits, net of Federal tax effects.

Q: Where can I find more information about Stonehenge?
A: Stonehenge was formed in 1999 as a spin-off from Bank One's merger with First Chicago. Stonehenge's principals held key positions at Banc One Capital Markets. Stonehenge's conservative approach is a result of our banking legacy and is present today in Stonehenge's diligent approach to its business and the risk mitigation measures that it employs.