Epstein Secrets

gn country than to Puerto Rico. 4 4 I.R.C. Section 937. Thus, despite Puerto Rico's legal status as a U.S. territory, entities organized outside of the United States operating in Puerto Rico and bona fide residents of Puerto Rico will generally not be subject to U.S. Income tax on Puerto Rico source income. There

becomes a Puerto Rico resident will be 100 percent exempted from Puerto Rico income taxes. The 10-year rule is intended to work in conjunction with U.S. Treasury Regulations providing that gains from the disposition of certain property of former U.S. residents will be considered to be from sources outside of the U.S. po

with Gary and get back to me. Thanks Phil Philip J. Michaels I Partner Fulbright & Jaworski LLP 666 Fifth Avenue, New York, New York 10103-3198, United State [email protected] <mailto:[email protected]> NORTON ROSE FULBRIGHT EFTA_R1_00112760 EFTA01788359 La

ie R. Dyce Associate Duane Morris LLP 1540 Broadway New York, NY 10036-4086 2 EFTA_R1_00112761 EFTA01788360 E-MAI VCARD In compliance with U.S. Treasury Regulations, please be advised that any tax advice given herein (or in any attachment) was not intended or written to be used, and cannot be used, for the purpo

ct: RE: Siegal Ok. I am here all week. Phil Philip. Michaels I Partner Fulbright & Jaworski LLP 666 Fifth Avenue, New York, New York 10103-3198, United State NORTON ROSE FULBRIGHT Law around the world nortonrosefulbright.com <http://nortonrosefulbright.com/> EFTA_R1_01743588 EFTA02573518 Our website

orris.com> I BIO<http://duanemorris.com/attorneys/jamierdyce.html> I VCARD <http://www.duanemorris.com/attorneys/vCard/8407.vcf> In compliance with U.S. Treasury Regulations, please be advised that any tax advice given herein (or in any attachment) was not intended or written to be used, and cannot be used, for the purpo

marketing, or recommending=to another party any transaction or matter addressed herein.=/b> Richard Joslin, CPA Rothstein Kass 1350 Avenue of the Americas New York, NY 10019 Main: =21 Direct Tel: C: F: E-Mail: EFTA_R1_02108999 EFTA02708241 =/span> STATEMENT OF CONFIDENTIALITY The information

Subject: Signed offer letter= Forwarded message From: Joslin, Richard Date: Monday, September 30, 2013 Subj • To: ' In order to comply with U.S. Treasury Regulations governing tax practice (known as "Circular 230"), you are hereb= advised that any tax advice provided herein was not intended or written to be used,

tal combined voting power or total value of the corporation's stock on any day during any taxable year. If the Access Fund invests in a CFC and is a United States Shareholder, its Limited Partners who are U.S. persons will be subject to tax under the CFC rules. As a result, each such Limited Partner must inc

confidential information as are set forth in the Partnership Agreement Notwithstanding anything in this Memorandum to the contrary, to comply with U.S. Treasury Regulations Section 1.6011-4(b)(3)(i), each investor (and any employee, representative, or other agent of such investor) may disclose to any and all persons, w

tal combined voting power or total value of the corporation's stock on any day during any taxable year. If the Access Fund invests in a CFC and is a United States Shareholder, its Limited Partners who are U.S. persons will be subject to tax under the CFC rules. As a result, each such Limited Partner must inc

confidential information as are set forth in the Partnership Agreement Notwithstanding anything in this Memorandum to the contrary, to comply with U.S. Treasury Regulations Section 1.6011-4(b)(3)(i), each investor (and any employee, representative, or other agent of such investor) may disclose to any and all persons, w

tal combined voting power or total value of the corporation's stock on any day during any taxable year. If the Access Fund invests in a CFC and is a United States Shareholder, its Limited Partners who are U.S. persons will be subject to tax under the CFC rules. As a result, each such Limited Partner must inc

confidential information as are set forth in the Partnership Agreement Notwithstanding anything in this Memorandum to the contrary, to comply with U.S. Treasury Regulations Section 1.6011-4(b)(3)(i), each investor (and any employee, representative, or other agent of such investor) may disclose to any and all persons, w

tal combined voting power or total value of the corporation's stock on any day during any taxable year. If the Access Fund invests in a CFC and is a United States Shareholder, its Limited Partners who are U.S. persons will be subject to tax under the CFC rules. As a result, each such Limited Partner must inc

confidential information as are set forth in the Partnership Agreement Notwithstanding anything in this Memorandum to the contrary, to comply with U.S. Treasury Regulations Section 1.6011-4(b)(3)(i), each investor (and any employee, representative, or other agent of such investor) may disclose to any and all persons, w

tal combined voting power or total value of the corporation's stock on any day during any taxable year. If the Access Fund invests in a CFC and is a United States Shareholder, its Limited Partners who are U.S. persons will be subject to tax under the CFC rules. As a result, each such Limited Partner must inc

confidential information as are set forth in the Partnership Agreement Notwithstanding anything in this Memorandum to the contrary, to comply with U.S. Treasury Regulations Section 1.6011-4(b)(3)(i), each investor (and any employee, representative, or other agent of such investor) may disclose to any and all persons, w

s Shareholders under the CFC rules, and (ii) will be subject to the Section 1248 recharacterization rule described above. In addition, if the Fund is a United States Shareholder of a CFC and a U.S. Partner disposes of its Limited Partner Interest, that Partner generally will recognize income under Section 751 of t

tment in the Fund and as to applicable foreign, state, estate, and local taxes. General Matters Classification of the Fund - Pursuant to applicable U.S. Treasury Regulations, the Fund will be treated as a partnership, rather than a corporation, for U.S. federal income tax purposes unless the Fund affirmatively elects to b