Epstein File EFTA01392112: Warren, Asset and Offshore (DS10)

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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01392112: Warren, Asset and Offshore (DS10)

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This document is a confidential private placement memorandum addressing offshore fund taxation rules and asset disposal procedures for investors. It references the Taxation (International and Other Provisions) Act 2010 and the Offshore Funds (Tax) Regulations 2009, detailing how gains and losses on asset disposals are treated for UK tax purposes.

👤 Named in This Document

Warren

🔑 Evidence Keywords

asset offshore allowance memorandum

📋 Key Excerpts9

PersonKeyword

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