Epstein File EFTA00589225: Holder, Treat and Arrangement (DS9)

Epstein Index›Documents›EFTA00589225

⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA00589225: Holder, Treat and Arrangement (DS9)

General DocumentDate unavailableEFTA005892252 keyword hits

1

views

0

shares

0

reactions

1

persons

4

keywords

5

excerpts

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: 1.

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**