Epstein File EFTA01392372: Treat, Controlled and Cayman Islands (DS10)

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Epstein File EFTA01392372: Treat, Controlled and Cayman Islands (DS10)

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This document is a tax memorandum discussing 2017 Tax Legislation changes affecting the holding period for treating carried interest as capital gain. The document addresses limitations on interest deductibility, corporate tax rate changes, and controlled foreign corporation definitions. Maples and Calder is identified as Cayman Islands counsel for the Investment Manager and General Partner.

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treat controlled Cayman Islands memorandum

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Excerpt 1

Finally, the 2017 Tax Legislation increased the holding period required in order for professionals to **treat** carried interest as capital gain, which may

Excerpt 2

things, (i) limitations on the deductibility of net interest expense, (ii) changes in the corporate tax rate, (iii) an expansion of the definition of **controlled**

Excerpt 3

Maples and Calder currently serves as **Cayman** **Islands** counsel for the Investment Manager and the General Partner.