Epstein File EFTA00961156: Holder (DS9)

Epstein Index›Documents›EFTA00961156

⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA00961156: Holder (DS9)

General DocumentDate unavailableEFTA009611561 keyword hits

0

views

0

shares

0

reactions

1

persons

1

keywords

3

excerpts

This document is a tax analysis discussing partnership structure and income tax flow-through treatment involving senior preferred interest holders and junior equity interest holders through grantor trusts. The excerpt addresses how income tax items flow to holders and the tax treatment of freeze partnership structures.

👤 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 EFTA00961156 separate existence of the junior equity interest **holder** should be sufficient to treat the partnership as a freeze partnership with two