Epstein Secrets

and contact information can be found at the end of the Alert. EFTA00851267 In January of this year, we circulated a Client Alert about an ongoing Internal Revenue Service audit of the US lending and stock distribution (underwriting) activities of an offshore hedge fund in which the IRS had determined that the offshor

the alert: http://www.sglawyers.com/admin/PDFs/347.PDF Recent Developments It was recently reported that the IRS issued a deficiency notice to the Cayman Islands hedge fund that was the subject of our prior Client Alert for over $102 million in US income tax. Last month, such hedge fund filed a petition with

ssued to me), and 2) I am not subject to backup withholding because: (a) I am exempt from backup withholding, or (b) I have not been notified by the Internal Revenue Service (IRS) that I am subject to backup withholding as a result of a failure to report all interest and dividends, or (c) the IRS has notified me that I a

count at the New York Branch of UBS AG, from which funds are then swept and re-deposited each business day into an overnight deposit account at the Cayman Islands branch of UBS AG. As your agent, UBS Financial Services Inc. will make the necessary withdrawals from the New York deposit account to satisfy debit

issued to me), and 2)1 am not subject to backup withholding because: (a) I am exempt from backup withholding, or (b) I have not been notified by the Internal Revenue Service (IRS) that I am subject to backup withholding as a result of a failure to report all interest and dividends. or (c) the IRS has notified me that I a

count at the New York Branch of UBS AG, from which funds are then swept and re-deposited each business day into an overnight deposit account at the Cayman Islands branch of UBS AG. As your agent, UBS Financial Services Inc. will make the necessary withdrawals from the New York deposit account to satisfy debit

issued to me), and 2)1 am not subject to backup withholding because: (a) I am exempt from backup withholding, or (b) I have not been notified by the Internal Revenue Service (IRS) that I am subject to backup withholding as a result of a failure to report all interest and dividends, or (c) the IRS has notified me that I a

count at the New York Branch of UBS AG, from which funds are then swept and re-deposited each business day into an overnight deposit account at the Cayman Islands branch of UBS AG. As your agent, UBS Financial Services Inc. will make the necessary withdrawals from the New York deposit account to satisfy debit

ssued to me), and 2) I am not subject to backup withholding because: (a) I am exempt from backup withholding, or (b) I have not been notified by the Internal Revenue Service (IRS) that I am subject to backup withholding as a result of a failure to report all interest and dividends, or (c) the IRS has notified me that I a

count at the New York Branch of UBS AG, from which funds are then swept and re-deposited each business day into an overnight deposit account at the Cayman Islands branch of UBS AG. As your agent, UBS Financial Services Inc. will make the necessary withdrawals from the New York deposit account to satisfy debit

issued to me), and 2)1 am not subject to backup withholding because: (a) I am exempt from backup withholding, or (b) I have not been notified by the Internal Revenue Service (IRS) that I am subject to backup withholding as a result of a failure to report all interest and dividends, or (c) the IRS has notified me that I a

count at the New York Branch of UBS AG, from which funds are then swept and re-deposited each business day into an overnight deposit account at the Cayman Islands branch of UBS AG. As your agent, UBS Financial Services Inc. will make the necessary withdrawals from the New York deposit account to satisfy debit

ssued to me), and 2) I am not subject to backup withholding because: (a) I am exempt from backup withholding, or (b) I have not been notified by the Internal Revenue Service (IRS) that I am subject to backup withholding as a result of a failure to report all interest and dividends, or (c) the IRS has notified me that I a

count at the New York Branch of UBS AG, from which funds are then swept and re-deposited each business day into an overnight deposit account at the Cayman Islands branch of UBS AG. As your agent, UBS Financial Services Inc. will make the necessary withdrawals from the New York deposit account to satisfy debit

issued to me), and 2) lam not subject to backup withholding because: (a) I am exempt from backup withholding, or (b) I have not been notified by the Internal Revenue Service (IRS) that I am subject to backup withholding as a result of a failure to report all interest and dividends, or (c) the IRS has notified me that I a

count at the New York Branch of UBS AG, from which funds are then swept and re-deposited each business day into an overnight deposit account at the Cayman Islands branch of UBS AG. As your agent, UBS Financial Services Inc. will make the necessary withdrawals from the New York deposit account to satisfy debit

Appellee. No. 90-6034. United States Court of Appeals, Eleventh Circuit. Oct. 22, 1991. Member of Church of Scientology filed complaint against Internal Revenue Service (IRS) seeking tax refunds on grounds that IRS inconsistently administered charitable deductions for quid pro quo payments to religious organizati

transactional" and "use" im- munity for the information he provided. The magistrate also determined that Har- vey had told the government about the Cayman Islands funds. The majority ap- parently takes comfort from this finding, stating "we are working solely with the familiar categories of transactional and