Epstein File EFTA01354211: Treat and Controlled (DS10)

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Epstein File EFTA01354211: Treat and Controlled (DS10)

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Document containing tax code language regarding Section 1248 and how Limited Partners must treat distributive shares, along with references to controlled foreign corporations and Henry Nicholas. The document appears to address tax treatment of partnership interests and controlled entities.

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treat controlled

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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

GLDUS143 Henry Nicholas **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**