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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01392020: Warren and Treat (DS10)

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This document contains a reference to Section 1248 of the Code regarding Limited Partner treatment of distributive shares and gain realization, and mentions Glenn Warren in connection with Controlled Foreign Corporations. The excerpt appears to be from a legal or tax document but lacks sufficient context to determine its full relevance.

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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
GLDUS144 Glenn **Warren** Controlled Foreign Corporations.

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