Epstein Index›Documents›EFTA01450384
⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01450384: Holder and Treat (DS10)

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Financial or legal document concerning the treatment of Notes for U.S. federal income tax purposes, with references to tax counsel Morrison & Foerster LLP and Section 988 election provisions. The document outlines how holders must identify and treat the investment in Notes on their books and records.

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🔑 Evidence Keywords

📋 Key Excerpts6

PersonKeyword
Excerpt 1
We intend to **treat** the Notes consistent with this approach.
Excerpt 2
Pursuant to the terms of the Notes, you agree to **treat** the Notes under this approach for all U.S. federal income tax purposes.
Excerpt 3
based on certain factual representations received from us, in the opinion of our special U.S. tax counsel, Morrison & Foerster LLP, it is reasonable to **treat**

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