💨IMPACT LEVEL 1 — MEH
Epstein File EFTA01383072: Asset, Offshore and Allowance (DS10)
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This is a confidential private placement memorandum for an offshore fund describing asset disposition, tax treatment, and investor cost basis calculations. The document references UK tax regulations including the Taxation (International and Other Provisions) Act 2010 and the Offshore Funds (Tax) Regulations 2009, outlining how capital gains and losses are treated for offshore fund investors.
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Excerpt 1
Upon the Fund disposing of an **asset** to a third party, each Investor will be treated as disposing of its share in that **asset**.
Excerpt 2
base cost of each Investor in each of the assets will, for the purposes of computing any
gain or loss on a subsequent disposal or part-disposal of the **asset**
Excerpt 3
, be the market value of the **asset** at the date of
distribution, reduced by the notional gain which would have arisen if the **asset** had been disposed of
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