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Although investment partnerships are generally not investment companies as de ned in federal securities laws, they do meet the de nition of investment companies as contained in the Audit Guide Accordingly, the Audit Guide is generally applicable to investment partnerships There are, however, certain disclosure requirements in the Audit Guide to which most partnerships have historically taken exception and have not followed The AICPA clari ed the appropriate disclosure for partnerships in its issuance of SOP 95-2, Financial Reporting for Nonpublic Investment Partnerships, as amended by SOP 01-1, Amendment to Scope of Statement of Position 95-2, which is applicable for scal years beginning after December 15, 1994 A partnership is classi ed as a pass-through entity for tax purposes, meaning that the partners, not the partnership, are taxed on the income, expenses, gains, and losses incurred by the partnership The partners recognize the tax effects of the partnership s operations regardless of whether any distribution is made to such partners This differs from a corporation, which incurs an entity level tax on its earnings and whose owners (stockholders) incur a second level of tax when the corporation s pro ts are distributed to them (h) OFFSHORE FUNDS SPECIAL CONSIDERATIONS Offshore funds may be described generally as investment funds set up to permit international investments with minimum tax burden on the fund shareholders This is achieved by setting up the funds in countries with favorable tax laws, as well as in countries with nonburdensome administrative regulations Popular offshore locations include Bermuda, the Cayman Islands, and the Netherlands Antilles An offshore fund s shares are offered to investors (generally non-US) residing outside the country in which the fund is domiciled Assuming the offshore fund is not publicly sold in the United States and does not have more than 100 US shareholders (or only quali ed purchasers ), the offshore fund will not be subject to SEC registration or reporting requirements Similar to hedge funds, because of the lack of regulatory restrictions, offshore funds often have higher risk investment strategies than US regulated funds A major US tax advantage to non-US shareholders of investing in US securities through an offshore fund as opposed to a US domiciled fund is the avoidance of certain US withholding taxes By investing through the offshore fund, the shareholder avoids withholding taxes on most US-sourced interest income and short-term capital gains, which would be subject to withholding taxes if the amounts were paid to the non-US shareholder through a US domiciled fund Offshore funds also avoid the US Internal Revenue Code distribution requirements imposed on US funds This allows for the potential roll-up of income in the fund (ie, the deferral of income recognition for the shareholder for tax purposes, depending on the tax residence of the shareholder) Under new tax legislation, a fund s US administrative and other activities, which were previously required to be performed offshore to comply with IRC Reg Sec 1864 2(c)2 (the Ten Commandments ), generally will not create tax nexus for US federal income tax purposes However, depending on the laws of the particular jurisdiction in which its US activities are conducted, those same US activities may under some circumstances create tax nexus in certain state or local jurisdictions Careful consideration should be given to the potential state and local tax consequences of onshore activities before any activities that were previously recommended to be conducted outside the United States are brought onshore Fund managers and advisers should consider several nontax factors before bringing certain functions onshore These include the following:.

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'\141'

Table 101 Policy Overview with Direct Link and One Provider INTERNAL DATA CENTER East West PREFERRED Direct Direct BACKUP ISP1 to West ISP1 to East EXTERNAL PREFERRED ISP East POP ISP West POP BACKUP ISP West POP to Direct ISP East POP to Direct

'a' '&' '0'

Whether the performance of more operations onshore will make it more likely that the fund,

'\46' '\60'

manager, and/or advisers can be subject to the jurisdiction of US courts and/or applicable US, state, or local laws and regulations The regulatory requirements of the fund s domicile (eg, Luxembourg, Dublin, and Bermuda require administration and certain other functions to be performed locally) The investor s desire for con dentiality The potential applicability of federal, state, and local tax or other ling requirements The potential effect on prospectus disclosure

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A string literal is a sequence of characters which must be enclosed in double quotes and must occur on a single line All string literals are objects of the class String (see Section 104, p 439) Escape sequences as well as Unicode values can appear in string literals:

10 Table 102 Per-Router BGP Configuration Worksheet for Medical World AS NUMBER 64001 64001 ROUTER NAME (YOUR ADMINISTRATIVE ID) West East

"Here comes a tab\t And here comes another one\u0009!" "What's on the menu " "\"String literals are double-quoted\"" "Left!\nRight!" "Don't split me up!"

31 58

(1) (2) (3) (4) (5)

.

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Medical World s Internet users, as well as the Internet backup for the East-toWest server link, become increasingly subtle Backup for the Internet users is relatively straightforward Each site advertises its Internet access addresses with a community indicating that it is the preferred destination for these routes Each also advertises the other s block, but with a much worse preference Internally, each site has the other site s router as the next hop on the dedicated link If that link goes down, the next hop for the other site s routes will not be resolvable, and the site will stop advertising the less preferred other side addresses Backing up the link is more complex Each site can advertise that it can reach the server farm at the other site, but its advertisements will show the private AS number as its origin Without the provider stripping the AS number such that the carrier AS shows as the origin, the other Medical World site would reject the advertisement as containing its own AS in the path, a violation of BGP loop detection rules Private AS stripping is not standard, although available on several vendors products Another strategy might be to give different private AS numbers to both sites, although that certainly would interfere with an RFC 2270 strategy by the carrier

In (1), the tab character is specified using the escape sequence and the Unicode value, respectively In (2), the single apostrophe need not be escaped in strings, but it would be if specified as a character literal ('\'') In (3), the double quotes in the string must be escaped In (4), we use the escape sequence \n to insert a newline (5) generates a compile time error, as the string literal is split over several lines Printing the strings from (1) to (4) will give the following result:

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