Subject: Fwd: YGPF
From: Cheryl Mills <[email-masked]>
To: Tina Flournoy <[email-masked]>
Cc: John Podesta <[email-masked]>, Heather Samuelson <[email-masked]>
Date: Wed, 20 Jan 2016 14:54:12 -0500

Tina

This comes from 2007/2008 Q/A about WJC Yucapia relationship and taxes.

cdm
---------- Forwarded message ----------
From: Heather Samuelson <[email-masked]>
Date: Wed, Jan 20, 2016 at 2:41 PM
Subject: YGPF
To: Cheryl Mills <[email-masked]>

Q.  Why is YGPF organized in the Cayman Islands?

A.  The Yucaipa Global Partnership Fund invests in foreign corporations and
welcomes foreign investors.

      To avoid double taxation -- where investors are taxed in two
countries on the same income without an offsetting foreign tax credit in
the investor's home country -- YGPF, like many international funds, is
organized in the Cayman Islands.

      Taxable U.S. investors in funds organized in the Cayman Islands pay
applicable U.S. taxes on income and gain from those funds, but are not
subject to being taxed a second time on that same income or gain by the
Cayman Islands.

      As an American citizen, President Clinton must and does pay all
applicable U.S. taxes on all the income or gains he receives related to the
Yucaipa Global Partnership Fund.