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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA01344609: Treat (DS10)

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This document contains correspondence regarding the tax treatment of Notes, referencing an agreement between parties to treat the Notes consistently for U.S. federal income tax purposes. The document cites an opinion from tax counsel Morrison & Foerster LLP regarding the reasonable treatment of the Notes based on factual representations received.

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We intend to **treat** the Notes consistent with this approach.
Excerpt 2
Pursuant to the terms of the Notes, you agree to **treat** the Notes under this approach for all U.S. federal income tax purposes.
Excerpt 3
based on certain factual representations received from us, in the opinion of our special U.S. tax counsel, Morrison & Foerster LLP, it is reasonable to **treat**

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