Epstein File EFTA00961136: Holder, Structuring and Treat (DS9)

Epstein Index›Documents›EFTA00961136

⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA00961136: Holder, Structuring and Treat (DS9)

Financial RecordDate unavailableEFTA009611361 keyword hits

0

views

0

shares

0

reactions

1

persons

2

keywords

5

excerpts

This document discusses tax planning strategies involving partnership structuring and freeze partnerships. It references creating a junior equity interest holder entity (EFTA00961136) to treat a partnership as a freeze partnership with multiple tiers of ownership. The document explains how income tax items would flow through to holders of senior preferred interests and junior equity interests via grantor trusts. The excerpt focuses on technical tax treatment mechanisms for estate and income tax purposes.

👤 Named in This Document

Eric Holder

🔑 Evidence Keywords

structuring treat

📋 Key Excerpts5

PersonKeyword

Excerpt 1

The basis step up uncertainty can be avoided by some **structuring** if a freeze partnership is created to keep the liabilities with the boys by treating the

Excerpt 2

The separate existence of the junior equity interest holder EFTA00961136 should be sufficient to **treat** the partnership as a freeze partnership with two

Excerpt 3

All of the income tax items (except for the small percentageowned by others) would flow through to them either directly as the **holder** of the senior preferred