The memorandum addresses the incorrect titling of an investment intended for Financial Trust Company, Inc. (FTC) but titled in Jeffrey Epstein's name. It discusses the formation of The Haze Trust (THT) and its investments in hedge funds, including Highbridge Capital Corporation (HCC). The document examines tax implications, including the section 1294 election and potential eligibility for the Economic Development Commission (EDC) credit. It concludes that the transfer of interest to Southern Financial, LLC did not terminate the section 1294 election and explores the eligibility of deferred tax for the EDC credit.
documents/EFTA01128412.pdf
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