Epstein File EFTA01100198: Treat, Cayman Islands and Highbridge Capital (DS9)

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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA01100198: Treat, Cayman Islands and Highbridge Capital (DS9)

Financial RecordDate unavailableEFTA011001981 keyword hits

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A tax form or document related to Passive Foreign Investment Company (PFIC) elections and Qualified Electing Fund (QEF) designations for the calendar year 2012, referencing an address at Ugland House, George Town, Grand Cayman, Cayman Islands, and mentioning Highbridge Capital. The document contains multiple election provisions under U.S. tax law regarding treatment of foreign investment entities.

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🔑 Evidence Keywords

treat Cayman Islands Highbridge Capital calendar controlled

📋 Key Excerpts6

PersonKeyword

Excerpt 1

A X Election To **Treat** the PFIC as a QEF. I, a shareholder of a PFIC, elect to **treat** the PFIC as a OEF. Complete lines 6a through 7c of Part III.

Excerpt 2

I, a shareholder on the first day of a PFIC's first tax year as a QEF that is a controlled foreign corporation (CFC), elect to **treat** an amount equal to

Excerpt 3

I, a shareholder of a former PFIC or a PFIC to which section 1297(d) applies, elect to **treat** as an excess distribution the gain recognized on the deemed