Epstein Index›Documents›EFTA01366398
⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01366398: Holder, Backup and Withheld (DS10)

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This document discusses tax implications for non-U.S. holders of securities, specifically addressing how gains are taxed when connected to U.S. trade or business. The text outlines conditions under which a non-U.S. holder might recognize taxable gains from selling or exchanging securities.

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📋 Key Excerpts9

PersonKeyword
Excerpt 1
the gain is effectively connected with the conduct of a trade or business by the Non-U.S. **holder** within the United States (and, under certain income tax
Excerpt 2
treaties, is attributable to a United States permanent establishment or fixed base maintained by the Non-U.S. **holder**); or we are or have been a "U.S.
Excerpt 3
If the second bullet point above applies to a Non-U.S. **holder**, gain recognized by such **holder** on the sale, exchange or other disposition of our common

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