Epstein File EFTA02676202: Holder, Graham and Treat (DS11)

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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA02676202: Holder, Graham and Treat (DS11)

General DocumentDate unavailableEFTA026762021 keyword hits

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Document discussing tax treatment of stock options and transaction agreements, referencing IRC Section 305, Tax Receivable Agreements (TRAs), and companies including Graham Packaging Company Inc., Duff & Phelps Corporation, and Berry Plastics Corporation. The document addresses basis calculations and purchase price adjustments in business transactions.

👤 Named in This Document

Eric Holder Lindsey Graham

🔑 Evidence Keywords

treat

📋 Key Excerpts5

PersonKeyword

Excerpt 1

the transaction, the public company generally obtains additional basis in the underlying assets as payments under the In this case, IRC Section 305 may **treat**

Excerpt 2

value of a historic TAX TREATMENT OF STOCK OPTION TRAs equity owner's rights under the TRA (which is based on a In the Endo TRA, the parties agreed to **treat**

Excerpt 3

It is not uncommon for the seller of a business Alternatively, if the stock held by a historic equity **holder** is to seek an increase in purchase price in