HOUSE_OVERSIGHT_024088.jpg
2.89 MB
Extraction Summary
2
People
3
Organizations
1
Locations
0
Events
1
Relationships
3
Quotes
Document Information
Type:
Financial/legal document (private placement memorandum or partnership agreement tax disclosure)
File Size:
2.89 MB
Summary
This document is page 77 of a confidential financial disclosure (likely a Private Placement Memorandum) bearing a House Oversight Bates stamp. It details complex U.S. tax compliance rules for investors ('U.S. Partners') in 'The Fund,' specifically regarding Passive Foreign Investment Companies (PFIC) and Controlled Foreign Corporations (CFC) under Sections 951 through 957 of the Tax Code. It warns investors of potential tax liabilities on earnings from non-U.S. corporations even if those earnings are not distributed.
People (2)
| Name | Role | Context |
|---|---|---|
| U.S. Partners | Investors |
Investors in 'The Fund' who may be subject to specific tax liabilities regarding PFICs and CFCs.
|
| United States Shareholder | Legal Definition |
Defined as a person owning 10% or more of the voting power of a non-U.S. corporation.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Fund |
The investment entity issuing this document to investors.
|
|
| IRS |
Internal Revenue Service, mentioned regarding filing requirements.
|
|
| House Oversight Committee |
Implied by the Bates stamp 'HOUSE_OVERSIGHT_024088'.
|
Locations (1)
| Location | Context |
|---|---|
|
Jurisdiction for tax laws discussed.
|
Relationships (1)
Document outlines tax liabilities passed from the Fund to the Partners.
Key Quotes (3)
"The Fund cannot predict with any certainty at this time whether any non-U.S. portfolio company in which the Fund invests may be subject to the PFIC regime"Source
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Quote #1
"For this purpose, the Fund will be treated as a United States Shareholder of any foreign corporation in which the Fund’s share ownership reaches this 10% threshold."Source
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Quote #2
"CONTROL NUMBER 257 - CONFIDENTIAL"Source
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Quote #3
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