Epstein File EFTA01382997: Treat and Controlled (DS10)

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Epstein File EFTA01382997: Treat and Controlled (DS10)

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This document is a tax or partnership agreement excerpt discussing how Limited Partners must treat distributive shares of gains under Section 1248 of the Internal Revenue Code, and references to controlled foreign corporations and United States Shareholders. The excerpt mentions Southern Financial LLC but contains no substantive case information or specific transaction details.

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treat controlled

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PersonKeyword

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

GLDUS238 SOUTHERN FINANCIAL LLC **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**