Epstein File EFTA01393683: Asset, Offshore and Allowance (DS10)

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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA01393683: Asset, Offshore and Allowance (DS10)

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This document is a confidential private placement memorandum describing the tax treatment and fund structure for offshore investments, including provisions from the Taxation (International and Other Provisions) Act 2010 and the Offshore Funds (Tax) Regulations 2009. It outlines how investors are treated when assets are disposed of, how base costs are calculated for capital gains purposes, and the UK tax implications of offshore fund investments.

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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