Epstein File EFTA01451519: Holder, Memorandum and Offshore (DS10)

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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01451519: Holder, Memorandum and Offshore (DS10)

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This is a confidential private placement memorandum addressing tax considerations for holders of interests in onshore and offshore feeder funds. The document discusses U.S. tax-exempt investors and non-U.S. investors, defining beneficial owners and addressing ERISA considerations and IRS rulings applicable to the fund structure.

👤 Named in This Document

Eric Holder

🔑 Evidence Keywords

memorandum offshore beneficial owner controlled

📋 Key Excerpts8

PersonKeyword

Excerpt 1

, published rulings of the Internal Revenue Service (the "IRS"), court decisions and other applicable authority, all as in effect on the date of this **Memorandum**

Excerpt 2

Holders (as defined herein) and of Interests in the **Offshore** Feeder Fund by U.S. Tax-Exempt Investors (as defined herein) and Non-U.S.

Excerpt 3

discussion of tax considerations under "ERISA Considerations" have been written to support the marketing of investments in the Onshore Feeder Fund and the **Offshore**