Epstein File EFTA01393400: Asset, Offshore and Allowance (DS10)

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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA01393400: Asset, Offshore and Allowance (DS10)

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This document is a confidential private placement memorandum outlining fund asset disposal procedures, investor tax basis calculations, and offshore fund taxation rules under UK law. It specifies how investors are treated when fund assets are disposed of, how market value adjustments affect capital gains, and references the Taxation (International and Other Provisions) Act 2010 and Offshore Funds (Tax) Regulations 2009. The document contains standard fund legal and tax provisions with no apparent connection to Epstein.

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asset offshore allowance memorandum

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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