Epstein Index›Documents›EFTA01369896
⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01369896: Holder, Beneficial Owner and Classified (DS10)

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This document defines 'Holder' as a beneficial owner of shares meeting specific U.S. federal income tax criteria, including individuals who are U.S. citizens or residents and entities classified for tax purposes as partnerships or other structures. The document addresses tax treatment of hedging transactions, straddles, and controlled holdings, and establishes rules for calculating basis when holders acquire different share blocks at different times or prices.

👤 Named in This Document

📋 Key Excerpts6

PersonKeyword
Excerpt 1
Holder" means a **beneficial** **owner** of Shares that, for U.S. federal income tax purposes, is (a) an individual who is a citizen or resident of the United
Excerpt 2
hedging," "integrated," or "conversion" transaction or as a position in a "straddle" for U.S. federal income tax purposes; partnerships (including entities **classified**
Excerpt 3
voting power or value of the outstanding Shares; or persons holding Shares in connection with a trade or business conducted outside the United States: **controlled**

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