Epstein File EFTA01389729: Holder, Treat and Classified (DS10)

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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01389729: Holder, Treat and Classified (DS10)

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This document discusses tax implications for the Access Fund related to potential investments in non-U.S. corporations classified as Passive Foreign Investment Companies (PFICs). The text outlines specific conditions that would trigger PFIC classification, primarily based on the percentage of gross income from passive sources like interest and dividends. The document suggests that such investments could result in increased tax liability for Limited Partners.

👤 Named in This Document

Eric Holder

🔑 Evidence Keywords

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