Epstein Index›Documents›EFTA01392021
⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01392021: Warren, Withheld and Treat (DS10)

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This document is a limited partnership agreement excerpt from Glendower Capital (GLDUS144) addressing tax treatment for limited partners subject to U.S. federal income taxation. It discusses the election to treat foreign taxes as creditable or to claim deductions against U.S. federal taxable income. Glenn Warren is identified as associated with GLDUS144, and the document outlines tax withholding and crediting options for foreign tax obligations.

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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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