Epstein File EFTA01392381: Treat and Controlled (DS10)

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Epstein File EFTA01392381: Treat and Controlled (DS10)

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This document is a tax memorandum discussing Section 1248 of the Internal Revenue Code regarding how Limited Partners must treat portions of distributive shares and gains from the Access Fund. The document addresses treatment of controlled foreign corporations and U.S. shareholder status. Patrick Gerschel is identified as associated with this analysis.

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treat controlled memorandum

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Excerpt 1

In addition, under Section 1248 of the Code, each such Limited Partner must **treat** a portion of its distributive share of any gain realized by the Access

Excerpt 2

GLDUS128 Patrick Gerschel **Controlled** Foreign Corporations.

Excerpt 3

of the total combined voting power or total value of all classes of stock of a non-U.S. corporation (each, a "United States Shareholder") that is a "**controlled**