Epstein File EFTA01392019: Holder, Fifteen and Treat (DS10)

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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01392019: Holder, Fifteen and Treat (DS10)

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This document contains detailed tax and investment analysis regarding the Access Fund's treatment of debt investments, organizational expenses, and gain recognition. It discusses the fifteen-year amortization period for start-up expenses, ordinary income treatment of gains upon disposition, and various tax elections available to the holder regarding market discount income during the ownership period.

👤 Named in This Document

Eric Holder

🔑 Evidence Keywords

treat fifteen

📋 Key Excerpts5

PersonKeyword

Excerpt 1

Start-up and organizational expenses are generally amortized for U.S. federal income tax purposes over a **fifteen** (15) year period.

Excerpt 2

Upon disposition of such an obligation, the Access Fund generally would be required to **treat** gain recognized as ordinary income to the extent of the market

Excerpt 3

Any gain or loss realized on the disposition of debt investments may, depending upon the circumstances of the **holder** at the time of any such sale, be treated