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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA01386590: Treat, Controlled and Cayman Islands (DS10)

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This document discusses 2017 Tax Legislation changes affecting the holding period for professionals to treat carried interest as capital gains, limitations on net interest expense deductibility, corporate tax rate changes, and the expansion of controlled entity definitions. It identifies Maples and Calder as Cayman Islands counsel for the Investment Manager and General Partner.

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Finally, the 2017 Tax Legislation increased the holding period required in order for professionals to **treat** carried interest as capital gain, which may
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things, (i) limitations on the deductibility of net interest expense, (ii) changes in the corporate tax rate, (iii) an expansion of the definition of **controlled**
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Maples and Calder currently serves as **Cayman** **Islands** counsel for the Investment Manager and the General Partner.

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