Epstein Secrets

who is an individual will not be able to deduct losses from other "passive activities" against his or her share of income of the Partnership. Since the Master Fund may invest in the securities of foreign issuers, the Partnership's income may be subject to foreign income taxes, including withholding taxes. A Lim

tement" as part of its Federal income tax return for each year it participates in the "reportable transaction:" and (ii) send a copy of such form to the IRS Office of Tax Shelter Analysis at the time the first such tax return is filed. The scope of the Tax Shelter Regulations may be affected by further IRS guidance. Non-compliance wi

who is an individual will not be able to deduct losses from other "passive activities" against his or her share of income of the Partnership. Since the Master Fund may invest in the securities of foreign issuers, the Partnership's income may be subject to foreign income taxes, including withholding taxes. A Lim

tement" as part of its Federal income tax return for each year it participates in the "reportable transaction:" and (ii) send a copy of such form to the IRS Office of Tax Shelter Analysis at the time the first such tax return is filed. The scope of the Tax Shelter Regulations may be affected by further IRS guidance. Non-compliance wi

There is no assurance that the Fund will be able to obtain from any company that is a PFIC the necessary information, on an annual basis, to permit the Master Fund to make an election to treat any such PFIC as a QEF. The Fund also may have the option to elect to mark stock in a PFIC to market at the end of ever

mpleting Form 8886 ("Reportable Transaction Disclosure Statement") and filing it with its U.S. federal income tax return and a copy of the form with the IRS Office of Tax Shelter Analysis. At this time the Fund cannot predict whether any of its investments will require it or any of the Limited Partners to file Form 8886. If the Genera