Epstein File EFTA01451513: Holder and Offshore (DS10)

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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01451513: Holder and Offshore (DS10)

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This document contains excerpts from fund documentation describing the structure and tax treatment of an Offshore Feeder Fund and its relationship to an Onshore Feeder Fund. The document outlines that the Offshore Feeder Fund will be treated as a foreign corporation for U.S. federal income tax purposes and may be subject to U.S. tax if engaged in U.S. trade or business, with provisions addressing potential adverse tax consequences for investors who change residency status.

👤 Named in This Document

Eric Holder

🔑 Evidence Keywords

offshore

📋 Key Excerpts5

PersonKeyword

Excerpt 1

The term of the **Offshore** Feeder Fund is expected to end upon the dissolution and termination of the Onshore Feeder Fund.

Excerpt 2

The **Offshore** Feeder Fund will elect to be treated as a foreign corporation for U.S. federal income tax purposes.

Excerpt 3

In addition, if the **Offshore** Feeder Fund is treated as engaged in a U.S. trade or business, the **Offshore** Feeder Fund will generally be subject to U.S.