Epstein Secrets

rope Acquisitions and is based in London. Since joining Blackstone in 2011, Mr. Seppala has been involved in a number of Blackstone's investments in the United States and in Europe. Prior to joining Blackstone in 2011, Mr. Seppala was a Vice President at Goldman Sachs & Co, where he spent 10 years focused on equit

nds. Prior to joining Blackstone, Mr. Nash was with Merrill Lynch from 1997 to 2007 where he led the finn's Real Estate Principal Investment Group - Americas. Prior to 1997, Mr. Nash held various positions with Barclays Bank, Bank of Nova Scotia and Dcloitte Haskins & Sells. Mr. Nash received a B.S. in Ac

me, certain income from sales and services), regardless of cash distributions from the company. In addition, gain on the sale of the CFC's stock by a United States Shareholder (during the period that the corporation is a CFC and thereafter for a five-year period) would be classified in whole or in part as a div

g investments in "controlled %reign corporations" ("CFCs") and "passive foreign investment companies" ("PFICs"), both described immediately below. Controlled Foreign Corporations. If a U.S. Person, including any U.S. Limited Partner owns actually or constructively at least 10% of the voting stock of a non-U.S. corporation, su

otal 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 inclu

e 2017 Tax Legislation, the deferred earnings of certain foreign corporations will be deemed repatriated, and treated as if they were distributed to their United States Shareholders. Consequently, if the Access Fund invests in a foreign corporation and is a United States Shareholder, its Limited Partners who are U.

GLDUS238 SOUTHERN FINANCIAL LLC Controlled Foreign Corporations. Special rules apply to U.S. persons who own, directly or indirectly and applying certain attribution rules, 10% or more of the total combined votin

otal 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 inclu

e 2017 Tax Legislation, the deferred earnings of certain foreign corporations will be deemed repatriated, and treated as if they were distributed to their United States Shareholders. Consequently, if the Access Fund invests in a foreign corporation and is a United States Shareholder, its Limited Partners who are U.

GLDUS238 SOUTHERN FINANCIAL LLC Controlled Foreign Corporations. Special rules apply to U.S. persons who own, directly or indirectly and applying certain attribution rules, 10% or more of the total combined votin

otal 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 inclu

e 2017 Tax Legislation, the deferred earnings of certain foreign corporations will be deemed repatriated, and treated as if they were distributed to their United States Shareholders. Consequently, if the Access Fund invests in a foreign corporation and is a United States Shareholder, its Limited Partners who are U.

GLOUS144 Glenn Warren Controlled Foreign Corporations. Special rules apply to U.S. persons who own, directly or indirectly and applying certain attribution rules, 10% or more of the total combined votin

otal 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 inclu

e 2017 Tax Legislation, the deferred earnings of certain foreign corporations will be deemed repatriated, and treated as if they were distributed to their United States Shareholders. Consequently, if the Access Fund invests in a foreign corporation and is a United States Shareholder, its Limited Partners who are U.

GLDUS137 Forrestal Capital LLC Controlled Foreign Corporations. Special rules apply to U.S. persons who own, directly or indirectly and applying certain attribution rules, 10% or more of the total combined votin

VCs are not stock in the Issuer. However, no assurances can be given in this regard, and it is possible that a U.S. Holder of SVCs may be treated as a United States Shareholder. If the SVCs were treated as stock in the Issuer and the Issuer were treated as a CFC, a U.S. Holder of SVCs that is treated as a Unite

ns, including investments in "controlled foreign corporations" ("CFCs") and "passive foreign investment companies" ("PFICs"), both described below. Controlled Foreign Corporations. If a U.S. person owns, directly, indirectly or constructively, 10% or more of the combined voting power or value of the stock of a foreign corporat