💨IMPACT LEVEL 1 — MEH
Epstein File EFTA01390869: Asset, Offshore and Allowance (DS10)
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This document is a Confidential Private Placement Memorandum excerpt addressing offshore fund taxation and investor treatment of asset dispositions. It outlines UK tax treatment of capital gains and losses on asset dispositions, references the Taxation (International and Other Provisions) Act 2010 and Offshore Funds (Tax) Regulations 2009, and explains how investor cost basis is calculated upon asset distribution.
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Excerpt 1
Upon the Fund disposing of an **asset** to a third party, each Investor will be treated as disposing of its share in that **asset**.
Excerpt 2
base cost of each Investor in each of the assets will, for the purposes of computing any
gain or loss on a subsequent disposal or part-disposal of the **asset**
Excerpt 3
, be the market value of the **asset** at the date of
distribution, reduced by the notional gain which would have arisen if the **asset** had been disposed of
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