Epstein File EFTA01354210: Holder, Treat and Classified (DS10)

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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01354210: Holder, Treat and Classified (DS10)

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This document discusses tax implications related to The Access Fund's potential investments in non-U.S. corporations classified as Passive Foreign Investment Companies (PFICs). The document outlines specific tax conditions, specifically noting that if 75% or more of a corporation's gross income constitutes passive income like interest or dividends, it would be classified as a PFIC. Such an investment could potentially subject Limited Partners to increased tax liability.

👤 Named in This Document

Eric Holder

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classified treat

📋 Key Excerpts8

PersonKeyword

Excerpt 1

The Access Fund may invest in a non-U.S. corporation that is classified as a "passive foreign investment company" ("PFIC"), which would cause Limited Partners

Excerpt 2

In general, a non-U.S. corporation is classified as a PFIC if (i) 75% or more of its gross income constitutes "passive income" (generally, interest, dividends

Excerpt 3

If the Access Fund invests in a company that is classified as a PFIC, the Limited Partners may be subject to increased tax liability upon the Access Fund's