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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA00851267: Offshore and Cayman Islands (DS9)

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This is an email from Richard Kahn to Jeffrey Epstein dated July 15, 2015, forwarding a tax alert from Sadis & Goldberg Tax Group regarding a major IRS case involving U.S. lending activities of offshore funds. The alert reports that the IRS issued a deficiency notice to a Cayman Islands hedge fund for over $102 million in U.S. income tax, determining that the offshore fund was engaged in U.S. trade or business activities related to lending operations.

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From: Richard Kahn To: Jeffrey Epstein Subject: Fwd: Tax Alert: Major Tax Case on US Lending Activities of **Offshore** Funds Date:
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Forwarded message From: Sadis & Goldberg Tax Group Date: Wed, Jul 15, 2015 at 1:06 PM Subject: Tax Alert: Major Tax Case on US Lending Activities of **Offshore**
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hedge fund in which the IRS had determined that the **offshore** fund in question was engaged in a US trade or business both with respect to the lending and

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