Epstein Index›Documents›EFTA01459327
💨IMPACT LEVEL 1 — MEH

Epstein File EFTA01459327: Treat (DS10)

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This document is a tax opinion letter from special tax counsel regarding the treatment of notes as 'open transactions' rather than debt instruments based on current market conditions. The counsel provides a professional opinion on the appropriate tax classification of the notes under prevailing market circumstances.

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treatprofessional

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Based on current market conditions, in the opinion of our special tax counsel it is reasonable to **treat** the notes as "open transactions* that are not debt

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Source: U.S. Department of Justice

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