Epstein File EFTA01394654: Asset, Offshore and Allowance (DS10)

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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA01394654: Asset, Offshore and Allowance (DS10)

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This document is a confidential private placement memorandum excerpt detailing offshore fund tax treatment and regulations, specifically addressing how investors are treated upon asset disposal, cost basis calculations, and capital gains treatment under UK tax law and the Taxation (International and Other Provisions) Act 2010 and Offshore Funds (Tax) Regulations 2009. The document outlines the legal framework governing Epstein's offshore fund investments.

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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