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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01392499: Charles, Memorandum and Offshore (DS10)

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This document is a confidential private placement memorandum for an offshore fund governed by the Taxation (International and Other Provisions) Act 2010 and Offshore Funds (Tax) Regulations 2009. Key persons identified include Charles Smith, Carlo Pirzio-Biroli, Adam Graev, and Chi Cheung, with Smith and Pirzio-Biroli listed as managing partners. The memorandum includes standard partnership audit, legal, ERISA, and tax consideration provisions.

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PersonKeyword
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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