The document discusses the tax risks associated with the Onshore and Offshore Feeder Funds, including reporting and disclosure requirements, treaty benefits, PFIC status, and U.S. trade or business tax risks. It highlights the need for Limited Partners to obtain extensions for tax filings and the potential adverse tax consequences for U.S. Holders of the Offshore Feeder Fund.
doj/DataSet10/EFTA01451542.pdf
{"document_type":"financial","key_locations":["United States"],"document_subtype":"tax document","key_organizations":["Onshore Feeder Fund","Offshore Feeder Fund","Master Fund"],"reference_numbers":["DB-SDNY-0108203","SDNY_GM_00254387","EFTA01451542"]}