Epstein File EFTA00961142: Holder (DS9)

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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA00961142: Holder (DS9)

General DocumentDate unavailableEFTA009611421 keyword hits

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This document is a legal or tax analysis discussing the structure of partnership interests and income tax treatment. It describes how income tax items would flow through to holders of senior preferred interests and junior equity interests, and references the concept of a 'freeze partnership' with multiple interest holders, suggesting this is part of estate or financial planning documentation.

👤 Named in This Document

Eric Holder

🔑 Evidence Keywords

treat

📋 Key Excerpts3

PersonKeyword

Excerpt 1

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

Excerpt 2

interest, or indirectly from the nondisregarded junior equity interest **holder** through the grantor trusts as grantor.

Excerpt 3

The separate existence of the junior equity interest **holder** EFTA00961142 should be sufficient to treat the partnership as a freeze partnership with two