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Epstein File EFTA00630094: Structuring (DS9)

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This document references a Private Letter Ruling (PLR 201417007, released April 25, 2014) regarding tax-compliant Investment Development Funds (IDF) and outlines three basic elements for structuring such funds to achieve tax advantages for investors. The excerpt focuses on IRS guidance and tax compliance mechanics.

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recently published a Private Letter Ruling (PLR 201417007, released April 25, 2014) which provides some additional clarification with respect to the **structuring**
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The rules for **structuring** a tax-compliant IDF, whereby investors can reap the potentially substantial tax advantages, are comprised of three basic elements

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