Epstein Secrets

Gelinas, Daniel G. Viola Danielle Epstein-Day, Douglas Hirsc Erika Winkler Jamie Kim, Jeffrey Goldber

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

w. Alex Gelinas, Daniel G. Viol Danielle Epst: Douglas Hirsc Erika Winkler, Jeffrey Goldb Jennifer Ro

ra.)fl11 U.S. & U.K. FATCA - Due Diligence. In general, all financial accounts (including interests in investment entities) that were maintained by Cayman Islands investment entities as of June 30, 2014 have been classified as "pre-existing accounts" for U.S. and U.K. FATCA purposes. The due diligence require

te criminal prosecutions, the rule is stated in Douglas v. City of Jeannette, 819 U.S. 167, 163-164, 63

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