Epstein File EFTA01976726: Holder, Treat and Arrangement (DS10)

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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01976726: Holder, Treat and Arrangement (DS10)

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This document is a tax or estate planning memorandum discussing trust structures and debt arrangements. It describes a donor gifting Class B interests in an entity called Newco to a discretionary trust for the benefit of a spouse and issue, and analyzes how Section 2701 will treat such arrangements. The document compares an Intentional Grantor Trust (IBT) to debt arrangements and references Class A interests with a 1% annual non-cumulative return on a $5,000,000 redemption value.

👤 Named in This Document

Eric Holder

🔑 Evidence Keywords

treat arrangement client memorandum

📋 Key Excerpts5

PersonKeyword

Excerpt 1

Step #2 - Donor gifts her Class B interests in Newco to a discretionary trust for the benefit of her husband and issue. 4 Because section 2701 will **treat**

Excerpt 2

For many donors the IBT may be preferable to making the debt **arrangement** described above for the following reasons: 4 The use of a grantor trust as the

Excerpt 3

held by Newco exceeds the interest that would have been paid on the debt described above, the donees will be better off with the IBT than with the debt **arrangement**