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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01364724: Holder and Classified (DS10)

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A document discussing investment fund strategies, specifically detailing potential investments in non-U.S. corporations classified as Passive Foreign Investment Companies (PFICs) and associated tax implications for limited partners.

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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

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