purposes as a partnership and the following summary is based on that
assumption. HM Revenue & Customs will not treat the Fund as a separate taxable entity for UK income ... those of the Investors
as and when they arise. For this purpose, HM Revenue & Customs generally regards each Investor as owning a
fractional share of each of the Fund ... transparent for UK tax purposes (as
in the case of a partnership), HM Revenue & Customs will generally look through that investment to its underlying assets.
Each Investor will be solely
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01452022.pdf