This document provides information on the tax implications for Foreign Partners investing in the Partnership, particularly concerning U.S. Federal income tax, the HIRE Act, and estate tax. It outlines the conditions under which Foreign Partners may be subject to U.S. taxes and the requirements for compliance with the HIRE Act.
doj/DataSet10/EFTA01374112.pdf
{"key_people":["Paul Barrett"],"document_type":"correspondence","key_locations":["United States"],"document_subtype":"memo","key_organizations":["Alpha Group Capital","Partnership","Master Fund","IRS"],"reference_numbers":["Section 897","Section 1471(d)(4)"]}