EFTA01374619Set 10
2019-01-011p1,139w
Eligible gains. To enjoy OZ tax benefits, you must invest eligible capital gains in QOF shares. Eligible capital gains are gains from the sale of a capital asset,
such ... Investment within 180 days. To enjoy OZ tax benefits, you must invest in the QOF within 180 days of a taxable sale or exchange. The QOF's capital call,
however ... which the gain would otherwise have been recognized.
Tax risks while you hold the QOF investment
Loss of tax benefits if fund does not qualify as QOF
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01374619.pdf
EFTA01374621Set 10
2018-10-191p1,214w
CLOPRULES
THE PARALLEL LLCS ARE BEING FORMED FOR THE PURPOSE OF BENEFITING FROM THE QOF PROGRAM, AND EACH PRESENTLY INTENDS 70 CONDUCT ITS OPERATIONS SO THAT IT WILL
BE TREATED ... QOF WITHIN THE MEANING OF SUBCHAPTER Z OF THE TAX CODE. HOWEVER, NO ASSURANCES CAN BE PROVIDED THAT A PARALLEL LLC WILL QUAUFY M A QOF OR
THAT, EVEN ... WHAT MANNER THE TREASURY WILL RESOLVE THE MANY AREAS OF UNCERTAINTY IN THE
QOF PROGRAM. TECHNICAL CORRECTIONS LEGISLATION ALSO MAY BE NEEDED FROM CONGRESS TO CLARIFY CERTAIN PROVISIONS
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01374621.pdf
management team.
Risks Relating to the Uncertainty of and Compliance with the QOF Rules
The Fund was formed for the purpose of benefiting from the QOF program, and presently intends ... conduct its operations so that it Is treated as a QOF within the meaning of Subchapter Z of the U.S.
Internal Revenue Code. However, no assurances can be provided that ... Fund will qualify as a QOF or that, even if it does qualify, the tax benefits related to the QOF program will be available to any
particular investor
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01375673.pdf
management team.
Risks Relating to the Uncertainty of and Compliance with the QOF Rules
The Fund was formed for the purpose of benefiting from the QOF program, and presently intends ... conduct its operations so that it Is treated as a QOF within the meaning of Subchapter Z of the U.S.
Internal Revenue Code. However, no assurances can be provided that ... Fund will qualify as a QOF or that, even if it does qualify, the tax benefits related to the QOF program will be available to any
particular investor
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01378917.pdf
expected to be capitalized
with investors' eligible capital gains from prior investments.
• Generally, QOF investors are eligible for the following tax
benefits:
• Gain Deferral: QOF investors may defer ... prior eligible
capital gains until the earlier of the date on which the QOF investment
is sold or exchanged, or December 31, 2026.
Gain Reduction: Investors can have
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01374624.pdf