EFTA01111788Set 9
2009-03-1151p3,866w
withholding. Although
this exclusion will classify them as NFFEs, the Notice
indicates that no NFFE withholding will be required either.
— Certain holding companies
- Start-up companies
— Non-financial entities that ... subject to withholding) if they:
— specifically identify each individual, specified U.S.
person, or excepted NFFE that has an interest in such
entity,
— obtain from each such person the required
documentation ... financial foreign
entities" ("NFFEs") where the beneficial owner of the payment is an
NFFE, unless the NFFE provides the withholding agent with:
— the name, address, and TIN of each substantial
https://www.justice.gov/epstein/files/DataSet%209/EFTA01111788.pdf
EFTA00810362Set 9
38p18,246w
Section 1471(d)(4) of the Code or a non-financial foreign entity (an "NFFE") as
defined in Section 1472(d) of the Code. To avoid this withholding ... General Partner may reasonably request, that they are neither an FFI nor an NFFE, (b) if they are
an FFI, establish with the General Partner that they have entered into ... withholding requirements of Section 1471 of the Code, and (c) if they are an NFFE, certify that
they have no "substantial United States owners," disclose all information that the Fund
https://www.justice.gov/epstein/files/DataSet%209/EFTA00810362.pdf
EFTA01121910Set 9
129p88,846w
Section
1471(d)(4) of the Code or a non-financial foreign entity (an "NFFE") as defined in Section
1472(d) of the Code. To avoid this withholding ... General Partner may
reasonably request, that they are neither an FFI nor an NFFE, (b) if they are an FFI, establish with
the General Partner that they have entered into ... withholding
requirements of Section 1471 of the Code, and (c) if they are an NFFE, certify that they have no
"substantial United States owners," disclose all information that the Fund
https://www.justice.gov/epstein/files/DataSet%209/EFTA01121910.pdf
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https://www.justice.gov/epstein/files/DataSet%209/EFTA00110690.pdf