Epstein File EFTA01392014: Holder, Warren and Backup (DS10)

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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01392014: Holder, Warren and Backup (DS10)

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Tax guidance document addressing Limited Partner certifications, backup withholding requirements, and tax treatment of partnership interests. The document discusses capital asset treatment, nominee arrangements, and equity holder tax obligations for partnership investors.

👤 Named in This Document

Eric Holder Warren

🔑 Evidence Keywords

backup nominee asset

📋 Key Excerpts6

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**