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Epstein File EFTA01364726: Withheld and Treat (DS10)

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This document is partnership tax guidance explaining Limited Partners' options for treating foreign taxes withheld, including electing to claim foreign taxes as credits or deductions against U.S. federal taxable income. The excerpt addresses tax treatment alternatives available to Limited Partners subject to U.S. federal income taxation.

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Excerpt 1
applicable limitations, a Limited Partner that is subject to U.S. federal income taxation generally should be entitled to elect to treat foreign taxes **withheld**
Excerpt 2
Subject to applicable limitations, a Limited Partner that is subject to U.S. federal income taxation generally should be entitled to elect to **treat** foreign
Excerpt 3
Limited Partners that do not elect to **treat** their shares of foreign taxes as creditable generally may claim a deduction against U.S. federal taxable income

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