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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01354341: Charles, Memorandum and Offshore (DS10)

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This document is a confidential private placement memorandum describing an offshore fund structure. It identifies key persons and managing partners including Charles Smith, Carlo Pirzio-Biroli, Adam Graev, and Chi Cheung. The memorandum references offshore fund taxation rules under the Taxation (International and Other Provisions) Act 2010 and the Offshore Funds (Tax) Regulations 2009, and includes sections on legal, ERISA, and tax considerations.

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Excerpt 1
**Memorandum** This confidential private placement **memorandum**, as amended or supplemented from time to time.
Excerpt 2
Partnership Audit As defined in Section 9: Certain Legal, ERISA and Tax Considerations Rules Confidential Private Placement **Memorandum** 105 CONFIDENTIAL
Excerpt 3
**Offshore** Fund Rules The Taxation (International and Other Provisions) Act 2010 and the **Offshore** Funds (Tax) Regulations 2009.

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