Epstein Secrets

GLDUS140 Lawrence Hirsch IV. TAX, REGULATORY AND CERTAIN ERISA CO

ne or more U.S. persons have the authority to control all substantial decisions of the trust or (ii) has a valid election in effect under applicable U.S. Treasury Regulations to be treated as a U.S. person. If an entity treated as a partnership for U.S. federal income tax purposes holds the Interests, the U.S. federal in

GLDUS140 Lawrence Hirsch such amounts paid by a Limited Partner wi

tion and the Access Fund's tax basis in such debt before the modification. However, other than for certain "safe harbor" modifications specified in U.S. Treasury Regulations, the determination of whether a modification is "significant" is based on all of the facts and circumstances. Therefore, it is possible that the IRS

GLDUS140 Lawrence Hirsch UNLESS OTHERWISE INDICATED, REFERENCES IN

he Access Fund's income gain, loss and deduction are allocated so as to take into account the varying interests of the Partners in the Access Fund. U.S. Treasury Regulations provide that allocations of items of partnership income, gain, loss, deduction or credit will be respected for tax purposes if such allocations hav