Epstein File EFTA01391456: Asset, Offshore and Allowance (DS10)

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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA01391456: Asset, Offshore and Allowance (DS10)

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This document is a Confidential Private Placement Memorandum discussing offshore fund taxation and asset disposal rules under UK tax law. It outlines how investors are treated when funds dispose of assets, how cost basis is calculated, and references the Taxation (International and Other Provisions) Act 2010 and the Offshore Funds (Tax) Regulations 2009. The document addresses capital gains treatment and offshore fund compliance requirements.

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🔑 Evidence Keywords

asset offshore allowance memorandum

📋 Key Excerpts8

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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