Epstein File EFTA01353828: Holder and Classified (DS10)

Epstein Index›Documents›EFTA01353828

⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01353828: Holder and Classified (DS10)

Financial RecordDate unavailableEFTA013538281 keyword hits

0

views

0

shares

0

reactions

1

persons

1

keywords

7

excerpts

This document discusses tax implications for the Access Fund related to potential investments in non-U.S. corporations classified as Passive Foreign Investment Companies (PFICs). The text outlines specific conditions that would trigger PFIC classification, such as 75% or more of gross income being passive income like interest or dividends. The document suggests that Limited Partners could face increased tax liability if the Access Fund invests in such entities.

👤 Named in This Document

Eric Holder

🔑 Evidence Keywords

classified

📋 Key Excerpts7

PersonKeyword

Excerpt 1

The Access Fund may invest in a non-U.S. corporation that is classified as a "passive foreign investment company" ("PFIC"), which would cause Limited Partners

Excerpt 2

In general, a non-U.S. corporation is classified as a PFIC if (i) 75% or more of its gross income constitutes "passive income" (generally, interest, dividends

Excerpt 3

If the Access Fund invests in a company that is classified as a PFIC, the Limited Partners may be subject to increased tax liability upon the Access Fund's