HOUSE_OVERSIGHT_024084.jpg

2.75 MB
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Extraction Summary

2
People
4
Organizations
1
Locations
0
Events
1
Relationships
2
Quotes

Document Information

Type: Legal/financial document (offering memorandum or private placement memorandum)
File Size: 2.75 MB
Summary

This document is page 73 of a confidential offering memorandum or private placement memorandum for an unnamed investment fund ('The Fund'). It details U.S. federal income tax considerations and ERISA considerations, specifically outlining the 'Circular 230' disclaimer and the classification of the Fund as a partnership rather than a corporation for tax purposes. The document bears a 'HOUSE_OVERSIGHT' Bates stamp, indicating it was obtained during a congressional investigation.

People (2)

Name Role Context
The General Partner Fund Manager
Entity responsible for making tax election decisions for the Fund.
Partner Investor
Generic term used for investors holding interest in the Fund.

Organizations (4)

Name Type Context
The Fund
The investment entity being discussed in the document (specific name not visible on this page).
Internal Revenue Service (IRS)
U.S. tax authority mentioned in legal disclaimers.
U.S. Treasury
Government department whose regulations govern the tax practices discussed.
House Oversight Committee
Implied by the Bates stamp 'HOUSE_OVERSIGHT_024084', indicating this document is part of a congressional investigation.

Locations (1)

Location Context
Jurisdiction for the tax laws discussed.

Relationships (1)

The General Partner Management/Control The Fund
The General Partner has no intention of making such an election on behalf of the Fund

Key Quotes (2)

"THE INFORMATION... IS NOT INTENDED OR WRITTEN TO BE USED, AND CANNOT BE USED, BY THE INVESTORS FOR THE PURPOSE OF AVOIDING PENALTIES THAT THE INTERNAL REVENUE SERVICE... MAY ATTEMPT TO IMPOSE ON AN INVESTOR"
Source
HOUSE_OVERSIGHT_024084.jpg
Quote #1
"The General Partner has no intention of making such an election on behalf of the Fund and does not anticipate any circumstances under which such an election would be made."
Source
HOUSE_OVERSIGHT_024084.jpg
Quote #2

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