gbrain: sync converted org-mode brain files

ideas/asset-protection-structures.org

@@ -11,9 +11,9 @@ Research on corporate structures for a US-incorporated tech company with offshor
 
 The triad has three distinct asset classes, each with different protection needs:
 
-1. /IP (Logos):/ Passepartout codebase, gate rules, ACL2 proof libraries, the verification monopoly. This is the core defensible IP. Needs to be owned separately from the operating company so that if the operating company is sued, the IP is not reachable.
+1. /IP (Logos):/ Passepartout codebase, gate rules, ACL2 proof libraries, the [[file:verification-monopoly.org][verification monopoly]]. This is the core defensible IP. Needs to be owned separately from the operating company so that if the operating company is sued, the IP is not reachable.
 
-2. /Platform (Agora):/ The network itself — user base, reputation graph, contract history, protocol specification. This is harder to value and harder to protect because its value is partly in the user base. But the code, protocol spec, and network infrastructure can be owned separately.
+2. /Platform ([[file:agora.org][Agora]]):/ The network itself — user base, reputation graph, contract history, protocol specification. This is harder to value and harder to protect because its value is partly in the user base. But the code, protocol spec, and network infrastructure can be owned separately.
 
 3. /Revenue streams:/ Enterprise compliance contracts, transaction fees, PDS hosting subscriptions. These flow through the operating company. A judgment against the operating company attaches to the revenue in that entity.
 
@@ -35,7 +35,7 @@ Assessment: Fine for Phase 0. Upgrade when revenue exceeds liability risk tolera
 - Delaware C-Corp is the operating company (sells verification, runs the Agora PDS infrastructure)
 - A separate IP holding company in BVI, Cayman, or Nevis owns the Passepartout code, gate rules, ACL2 libraries, and the Agora protocol spec
 - The operating company licenses the IP from the holding company at arm's-length royalty rates
-- The holding company accumulates IP licensing revenue in the offshore jurisdiction
+- The holding company accumulates IP [[file:licensing.org][licensing]] revenue in the offshore jurisdiction
 
 Pros: Strong IP protection — a judgment against the operating company cannot reach the IP (the operating company doesn't own it). Profits from licensing are outside US tax jurisdiction until repatriated.
 Cons: US tax reform (TCJA 2017) introduced GILTI (Global Intangible Low-Taxed Income) — this structure is less tax-effective than pre-2017. Transfer pricing documentation required. Increases administrative complexity.
@@ -52,7 +52,7 @@ Cons: Complex, expensive to set up and maintain. Many investors are uncomfortabl
 ** Structure D: Delaware C-Corp + Delaware LLC Series + Offshore
 
 - Delaware C-Corp as parent
-- Each business line (Logos verification, Agora network, compute marketplace, PDS hosting) is a separate Delaware series LLC
+- Each business line (Logos verification, Agora network, [[file:compute-marketplace.org][compute marketplace]], PDS hosting) is a separate Delaware series LLC
 - IP held in an offshore company, licensed to each series LLC
 - Series LLCs protect assets within each series from liabilities arising in other series