Epstein File EFTA01382992: Holder, Backup and Nominee (DS10)

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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01382992: Holder, Backup and Nominee (DS10)

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This document is a tax guidance document for Limited Partners in an investment fund, discussing requirements for certifications to the Access Fund, backup withholding procedures, and the tax treatment of partnership interests. It addresses the status of equity holders, nominees, and the U.S. federal income tax implications for partnership structures and recommends consultation with tax advisors.

👤 Named in This Document

Eric Holder

🔑 Evidence Keywords

backup nominee asset

📋 Key Excerpts5

PersonKeyword

Excerpt 1

assumptions that each Limited Partner (i) will provide all appropriate certifications to the Access Fund in a timely fashion to minimize withholding, including **backup**

Excerpt 2

hold its Interests as a capital asset for U.S. federal income tax purposes, and (iii) holds its Interests for its own account and not as an agent or **nominee**

Excerpt 3

treated as a partnership for U.S. federal income tax purposes holds the Interests, the U.S. federal income tax treatment of the partnership and an equity **holder**