Epstein Files Search

EFTA01356755Dataset 10

1p428w

…the Fund to distribute to the Members any Distributable Proceeds received by the Fund within five (5) Business Days after the Fund's receipt thereof. 4.2 Distributions of Distributable Proceeds. 4.2.1 Any distribution of Distributable Proceeds pursuant to Section 4.1 shall be made as follows: (i) first, Distributable Proceeds shall be divided among all Members pro rata based on their respective Percentage Interests; (ii) second, the Distributable Proceeds apportioned to the Affiliated Members pursuant to clause…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01356755.pdf

EFTA01394894Dataset 10

2018-09-2636p17,724w

…Contributions 9 3.4 Default by Members 9 3.5 Capital Accounts 11 3.6 Return of Capital Contributions 11 4. DISTRIBUTIONS 11 4.1 Distributions Generally 11 4.2 Distributions of Distributable Proceeds 11 4.3 Tax Distributions 12 4.4 Limitations on Distributions 12 4.5 Withholding Taxes 13 4.6 Liability for Certain Taxes 13 5. ALLOCATIONS OF PROFITS AND LOSSES 13 5.1 Allocation of Profits and Losses 13 5.2 Regulatory Allocation Provisions 14 6…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01394894.pdf

EFTA01399366Dataset 10

2018-09-2670p17,721w

… 7 3.3 Capital Contributions. 9 3.4 Default by Members 9 3.5 Capital Accounts 11 3.6 Return of Capital Contributions 11 4. DISTRIBUTIONS EFTA01399367 11 4.1 4.2 4.3 Distributions Generally 11 Distributions of Distributable Proceeds 11 Tax Distributions 12 4.4 Limitations on Distributions 12 4.5 Withholding Taxes 13 4.6 Liability for Certain Taxes 13 5. 6. ALLOCATIONS OF PROFITS AND LOSSES 13 5.1 Allocation of Profits and Losses 13 5…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01399366.pdf

EFTA01374111Dataset 10

1p790w

…on the last business day of such taxable year. Gain or loss realized on Section 1256 contracts generally will be considered 60% long-term capital gain or loss and 40% short-term capital gain or loss. Pursuant to the "passive foreign investment company" ("PFIC") provisions of the Code, investments by the Master Fund in certain foreign corporations may cause a Limited Partner to (i) recognize taxable income prior to the receipt of distributable proceeds, (ii) pay an interest charge on…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01374111.pdf

EFTA01392474Dataset 10

1p947w

…Investor, and in particular may result in a U.S. Investor recognizing income subject to tax prior to the receipt by the Fund of any distributable proceeds. There can be no assurance that a QEF election will be available with respect to any PFIC in which the Fund directly or indirectly invests. U.S. Investors may be required to file an annual report with respect to any PFIC in which the Fund invests (including indirectly through a Fund Secondary). Controlled…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01392474.pdf

EFTA01393679Dataset 10

1p946w

…Investor, and in particular may result in a U.S. Investor recognizing income subject to tax prior to the receipt by the Fund of any distributable proceeds. There can be no assurance that a QEF election will be available with respect to any PFIC in which the Fund directly or indirectly invests. U.S. Investors may be required to file an annual report with respect to any PFIC in which the Fund invests (including indirectly through a Fund Secondary). Controlled…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01393679.pdf

EFTA01393928Dataset 10

1p947w

…Investor, and in particular may result in a U.S. Investor recognizing income subject to tax prior to the receipt by the Fund of any distributable proceeds. There can be no assurance that a QEF election will be available with respect to any PFIC in which the Fund directly or indirectly invests. U.S. Investors may be required to file an annual report with respect to any PFIC in which the Fund invests (including indirectly through a Fund Secondary). Controlled…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01393928.pdf

EFTA01364827Dataset 10

1p948w

…Investor, and in particular may result in a U.S. Investor recognizing income subject to tax prior to the receipt by the Fund of any distributable proceeds. There can be no assurance that a QEF election will be available with respect to any PFIC in which the Fund directly or indirectly invests. U.S. Investors may be required to file an annual report with respect to any PFIC in which the Fund invests (including indirectly through a Fund Secondary). Controlled…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01364827.pdf

EFTA01383069Dataset 10

1p948w

…Investor, and in particular may result in a U.S. Investor recognizing income subject to tax prior to the receipt by the Fund of any distributable proceeds. There can be no assurance that a QEF election will be available with respect to any PFIC in which the Fund directly or indirectly invests. U.S. Investors may be required to file an annual report with respect to any PFIC in which the Fund invests (including indirectly through a Fund Secondary). Controlled…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01383069.pdf

EFTA01391453Dataset 10

2018-01-011p946w

…Investor, and in particular may result in a U.S. Investor recognizing income subject to tax prior to the receipt by the Fund of any distributable proceeds. There can be no assurance that a QEF election will be available with respect to any PFIC in which the Fund directly or indirectly invests. U.S. Investors may be required to file an annual report with respect to any PFIC in which the Fund invests (including indirectly through a Fund Secondary). Controlled…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01391453.pdf

EFTA01391172Dataset 10

1p947w

…Investor, and in particular may result in a U.S. Investor recognizing income subject to tax prior to the receipt by the Fund of any distributable proceeds. There can be no assurance that a QEF election will be available with respect to any PFIC in which the Fund directly or indirectly invests. U.S. Investors may be required to file an annual report with respect to any PFIC in which the Fund invests (including indirectly through a Fund Secondary). Controlled…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01391172.pdf

EFTA01355238Dataset 10

1p947w

…Investor, and in particular may result in a U.S. Investor recognizing income subject to tax prior to the receipt by the Fund of any distributable proceeds. There can be no assurance that a QEF election will be available with respect to any PFIC in which the Fund directly or indirectly invests. U.S. Investors may be required to file an annual report with respect to any PFIC in which the Fund invests (including indirectly through a Fund Secondary). Controlled…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01355238.pdf

EFTA01353903Dataset 10

1p949w

…Investor, and in particular may result in a U.S. Investor recognizing income subject to tax prior to the receipt by the Fund of any distributable proceeds. There can be no assurance that a QEF election will be available with respect to any PFIC in which the Fund directly or indirectly invests. U.S. Investors may be required to file an annual report with respect to any PFIC in which the Fund invests (including indirectly through a Fund Secondary). Controlled…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01353903.pdf

EFTA01354742Dataset 10

1p947w

…Investor, and in particular may result in a U.S. Investor recognizing income subject to tax prior to the receipt by the Fund of any distributable proceeds. There can be no assurance that a QEF election will be available with respect to any PFIC in which the Fund directly or indirectly invests. U.S. Investors may be required to file an annual report with respect to any PFIC in which the Fund invests (including indirectly through a Fund Secondary). Controlled…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01354742.pdf

EFTA01394253Dataset 10

1p947w

…Investor, and in particular may result in a U.S. Investor recognizing income subject to tax prior to the receipt by the Fund of any distributable proceeds. There can be no assurance that a QEF election will be available with respect to any PFIC in which the Fund directly or indirectly invests. U.S. Investors may be required to file an annual report with respect to any PFIC in which the Fund invests (including indirectly through a Fund Secondary). Controlled…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01394253.pdf

EFTA01394650Dataset 10

1p947w

…Investor, and in particular may result in a U.S. Investor recognizing income subject to tax prior to the receipt by the Fund of any distributable proceeds. There can be no assurance that a QEF election will be available with respect to any PFIC in which the Fund directly or indirectly invests. U.S. Investors may be required to file an annual report with respect to any PFIC in which the Fund invests (including indirectly through a Fund Secondary). Controlled…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01394650.pdf

EFTA01386200Dataset 10

1p790w

…on the last business day of such taxable year. Gain or loss realized on Section 1256 contracts generally will be considered 60% long-term capital gain or loss and 40% short-term capital gain or loss. Pursuant to the "passive foreign investment company" ("PFIC") provisions of the Code, investments by the Master Fund in certain foreign corporations may cause a Limited Partner to (i) recognize taxable income prior to the receipt of distributable proceeds, (ii) pay an interest charge on…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01386200.pdf

EFTA01392108Dataset 10

1p947w

…Investor, and in particular may result in a U.S. Investor recognizing income subject to tax prior to the receipt by the Fund of any distributable proceeds. There can be no assurance that a QEF election will be available with respect to any PFIC in which the Fund directly or indirectly invests. U.S. Investors may be required to file an annual report with respect to any PFIC in which the Fund invests (including indirectly through a Fund Secondary). Controlled…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01392108.pdf

EFTA01354314Dataset 10

1p947w

…Investor, and in particular may result in a U.S. Investor recognizing income subject to tax prior to the receipt by the Fund of any distributable proceeds. There can be no assurance that a QEF election will be available with respect to any PFIC in which the Fund directly or indirectly invests. U.S. Investors may be required to file an annual report with respect to any PFIC in which the Fund invests (including indirectly through a Fund Secondary). Controlled…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01354314.pdf

EFTA01386679Dataset 10

1p948w

…Investor, and in particular may result in a U.S. Investor recognizing income subject to tax prior to the receipt by the Fund of any distributable proceeds. There can be no assurance that a QEF election will be available with respect to any PFIC in which the Fund directly or indirectly invests. U.S. Investors may be required to file an annual report with respect to any PFIC in which the Fund invests (including indirectly through a Fund Secondary). Controlled…

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01386679.pdf