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🌫️IMPACT LEVEL 2 — ROUTINE

Epstein File EFTA01451896: Offshore (DS10)

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This document discusses details about an Offshore Feeder Fund, specifically addressing potential tax implications and Treasury Department reporting requirements. It references potential prohibited tax shelter transactions and the conditions under which distributions from the offshore fund might occur.

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to distributions received from the Offshore Feeder Fund (which would occur generally only if a U.S.
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If the Offshore Feeder Fund engages in a prohibited tax shelter transaction, U.S.
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Treasury Department with respect to an investment in the Offshore Feeder Fund, U.S.

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