Epstein File EFTA01389298: Endowment, Memorandum and Backup (DS10)

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Epstein File EFTA01389298: Endowment, Memorandum and Backup (DS10)

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This document is a memorandum addressing tax, regulatory, and ERISA considerations for limited partners in an investment fund, specifically referencing the Georgetown University Endowment. It outlines requirements for certifications, backup withholding procedures, and tax treatment of interests held by limited partners, including provisions regarding nominee arrangements and capital asset treatment.

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memorandum backup nominee university endowment endowment asset

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Treasury Regulations, and judicial decisions and administrative interpretations thereunder, all as of the date of this **Memorandum**, all of which are subject

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assumptions that each Limited Partner (i) will provide all appropriate certifications to the Access Fund in a timely fashion to minimize withholding, including **backup**

Excerpt 3

hold its Interests as a capital asset for U.S. federal income tax purposes, and (iii) holds its Interests for its own account and not as an agent or **nominee**