Global Digital Solutions Inc (GDSI)

[Coreton]

looking at Brazilian tax law. The tax debt is the responsibility of the controlling party at the time it’s incurred. It’s not Bill or Rontan’s this will effect, its 100% the Bolzan’s.

Bolzan’s financially benefited from the tax evasion under Brazilian law and as adjudicated in this ruling. The Bolzan’s are 100% liable.

The tax liability was at not time conveyed upon the purchaser within the SPA. That would have been the only way it could be transfered from the Bolzan’s to GDSI or Rontan.