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2.87 MB
Extraction Summary
0
People
3
Organizations
1
Locations
0
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal/financial document (private placement memorandum or offering document)
File Size:
2.87 MB
Summary
Page 78 of a confidential financial offering document (likely a PPM) describing U.S. federal income tax consequences for investors ('Partners') in 'The Fund.' The text details complex regulations regarding Controlled Foreign Corporations (CFCs), the applicability of U.S. Foreign Tax Credits for taxes paid in other jurisdictions, and the tax treatment of Foreign Currency gains and losses. The document bears a 'HOUSE_OVERSIGHT' Bates stamp, indicating it was part of a congressional investigation.
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Fund |
The entity making investments and distributing shares to partners.
|
|
| General Partner |
The managing entity of the Fund.
|
|
| House Oversight Committee |
Indicated by the Bates stamp 'HOUSE_OVERSIGHT'.
|
Locations (1)
| Location | Context |
|---|---|
|
Tax jurisdiction and location of Partners.
|
Relationships (2)
Text refers to the General Partner's inability to provide assurance regarding the Fund's portfolio.
Text discusses U.S. Partners' distributive shares of Fund profits or losses.
Key Quotes (3)
"The General Partner cannot provide any assurance that the Fund’s portfolio companies will not be CFCs."Source
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Quote #1
"Foreign tax credits or deductions generally will not provide any benefit to tax-exempt U.S. Partners unless such Partners’ distributive shares... constitute 'unrelated business taxable income'"Source
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Quote #2
"CONTROL NUMBER 257 - CONFIDENTIAL"Source
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Quote #3
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