Epstein File EFTA00961150: Holder, Structuring and Treat (DS9)

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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA00961150: Holder, Structuring and Treat (DS9)

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A document discussing partnership structuring, basis step-up uncertainty, freeze partnerships, and tax treatment of equity interests and income flows. The document addresses how to structure partnerships to treat junior and senior equity interest holders differently for tax purposes, with references to grantor trusts.

👤 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 EFTA00961150 separate existence of the junior equity interest holder 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