Epstein File EFTA01391379: Holder, Treat and Classified (DS10)

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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01391379: 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 how a corporation might be classified as a PFIC if 75% or more of its gross income is passive income like interest or 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