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2.95 MB
Extraction Summary
0
People
4
Organizations
1
Locations
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Events
1
Relationships
4
Quotes
Document Information
Type:
Financial/legal document (likely private placement memorandum or offering memorandum)
File Size:
2.95 MB
Summary
This document is page 80 of a confidential financial or legal document, likely an Offering Memorandum, marked with a House Oversight bates stamp. It details U.S. federal income tax considerations for 'Non-U.S. Partners' investing in 'the Fund,' specifically covering withholding taxes, branch profits tax, tax treaties, and capital gains rules regarding U.S. sources and real property holding corporations (USRPHC).
Organizations (4)
| Name | Type | Context |
|---|---|---|
| The Fund | ||
| IRS | ||
| U.S. government | ||
| House Oversight Committee |
Locations (1)
| Location | Context |
|---|---|
Relationships (1)
Text discusses allocation of income and gains to Non-U.S. Partners from the Fund.
Key Quotes (4)
"If it were ultimately established that the Fund is engaged in a U.S. trade or business, the Fund generally would be required to withhold and remit to the U.S. government a percentage of the Fund’s net income"Source
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Quote #1
"Treatment of Interest and Dividends from U.S. Sources"Source
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Quote #2
"Treatment of the Fund’s Capital Gains from U.S. Sources"Source
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Quote #3
"CONTROL NUMBER 257 - CONFIDENTIAL"Source
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Quote #4
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