Epstein File EFTA01451879: Holder and Offshore (DS10)

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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01451879: Holder and Offshore (DS10)

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This document contains tax and structural information regarding an Offshore Feeder Fund and its relationship to an Onshore Feeder Fund. It discusses the expected termination of the Offshore Feeder Fund upon dissolution of the Onshore Feeder Fund, tax treatment of the Offshore Feeder Fund as a foreign corporation for U.S. federal income tax purposes, and potential adverse tax consequences for investors who change their U.S. tax holder status after investing in the Onshore Feeder Fund.

👤 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.