Epstein File EFTA00961144: Holder, Structuring and Treat (DS9)

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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA00961144: Holder, Structuring and Treat (DS9)

General DocumentDate unavailableEFTA009611441 keyword hits

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This document discusses tax planning strategies involving partnership structuring, including basis step-up avoidance through freeze partnerships and the treatment of junior and senior equity interests. It addresses income tax flow-through provisions and the separate existence of equity interest holders in a grantor trust arrangement.

👤 Named in This Document

Eric Holder

🔑 Evidence Keywords

structuring treat arrangement

📋 Key Excerpts5

PersonKeyword

Excerpt 1

The basis step up uncertainty can be avoided by some **structuring** if a freeze partnership is created to keep the liabilities with the boys, by treating

Excerpt 2

The separate existence of the junior equity interest holder EFTA00961144 should be sufficient to **treat** the partnership as a freeze partnership with two

Excerpt 3

All of the income tax items (except for the small percentageowned by others) would flow through to them either directly as the **holder** of the senior preferred