Planning Research Corp. of McLean and brokerage giant E. F. Hutton & Co. Inc. have joined forces to offer an investment opportunity in new technology that also offers the state-of-the-art in tax shelters.
The new venture, Hutton/PRC Technology Partners Ltd., is set up something like a venture-capital firm: it will collect money from investors--who will become limited partners--and put the cash into research and development efforts that years down the road could turn into moneymakers or flops.
A PRC spokesman said the projects to be funded would be research and development efforts being undertaken by existing companies, rather than "start-up" operations or projects of private inventors.
Using a format similar to many other research-and-development partnership tax shelters, investors in the PRC-Hutton venture should be able to deduct virtually all of the capital they contribute to the fund, the PRC spokesman said. Should the technology being developed prove successful, bringing royalty income to the investors, the income would be taxed as long-term capital gains, giving investors a further break, he said.
The PRC-Hutton effort is unique in its combination of a brokerage firm with a large professional and management services company at the top of the partnership. PRC will play a key role in searching out investments for the partnership and in overseeing the progress of the projects.
"PRC possesses technical expertise in a variety of disciplines," the offering's prospectus says. "This experience, coupled with PRC's role as system designer and project manager for a wide range of projects, provides PRC with experience relevant to the areas in which it will provide consulting services to the partnership."
Investors can participate in units of $500, but the minimum investment is $5,000. Hutton and PRC said they hope to raise between $10 million and $20 million through the partnership sale, although the top limit could be raised to $25 million. After expenses, the money would be used as investment capital in selected R&D projects, with profits, if any, returned in the form of royalties on inventions. Such a return could be years away, the prospectus says, making the deal best suited to patient, long-term investors. ccording to the prospectus, Hutton and PRC hope to return at least 300 percent of invested capital in the form of royalties, but it adds, "there can be no assurance that new technology or new products, not all of which may be patentable, will be successfully developed by the partnership, that such technology or new products, if developed, will be commercially successful or that the partnership will otherwise attain its investment objectives."
The prospectus also says that the tax advantages themselves are open to final interpretation by the Internal Reveune Service, and therefore risky. But E. F. Hutton is no stranger to tax shelters--it claims to be the nation's largest packager of tax shelters, and offered 100 different partnership arrangements in 1982 worth a total of more than $850 million.
E. F. Hutton First Vice President Timothy Kincaid, who serves as chairman of Hutton Services, the division that has joined together with PRC to make the new offering, went before the Senate finance committee's subcommittee on IRS oversight last week to defend tax shelters and Hutton's role in the industry. He said that although some shelters abuse the tax code, reputable ones "allow individual investors to directly participate and benefit from special investment incentives placed in the tax code . . . to serve important public purposes."