The document discusses tax considerations for investors in the Onshore Feeder Fund, Offshore Feeder Fund, and Master Fund, particularly in relation to non-U.S. income tax. It covers the implications of being treated as a resident or having a permanent establishment in foreign countries, the potential for withholding taxes, and the responsibilities of filing tax returns. It also addresses the treatment of withholding taxes as payments to Limited Partners and the possibility of capital gains taxes.
doj/DataSet10/EFTA01451525.pdf
{"document_type":"financial","document_subtype":"investment fund tax considerations","key_organizations":["Onshore Feeder Fund","Offshore Feeder Fund","Master Fund","Southern Financial LLC"],"reference_numbers":["DB-SDNY-0108179","SDNY_GM_00254363","EFTA01451525"]}