HOUSE_OVERSIGHT_024576.jpg
3.05 MB
Extraction Summary
1
People
2
Organizations
1
Locations
0
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal/financial document (tax disclosures/offering memorandum)
File Size:
3.05 MB
Summary
This page is part of a legal or financial document (page 143) detailing the tax implications for Limited Partners in an entity named 'KUE'. It outlines technical rules regarding nonrecourse liabilities, in-kind distributions, the calculation of tax basis for Common LP Units, limitations on deducting company losses, and specific withholding requirements (30%) for Non-U.S. persons. The document bears a House Oversight Committee Bates stamp.
People (1)
| Name | Role | Context |
|---|---|---|
| Prospective Investors | Target Audience |
Advised to consult tax advisors regarding deductibility of losses.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| KUE |
The company/partnership issuing units and distributing income/losses. Likely refers to KUE Capital or related entity.
|
|
| House Oversight Committee |
Source of the document (indicated by Bates stamp 'HOUSE_OVERSIGHT').
|
Locations (1)
| Location | Context |
|---|---|
|
Jurisdiction for tax laws and withholding rules.
|
Relationships (1)
References to 'Limited Partner's share of KUE losses' and 'distributions from KUE'.
Key Quotes (3)
"Non-U.S. Persons will be subject to U.S. withholding at a rate of 30%."Source
HOUSE_OVERSIGHT_024576.jpg
Quote #1
"The deduction by a Limited Partner of its share of Company losses will be limited to the adjusted tax basis in its Common LP Units."Source
HOUSE_OVERSIGHT_024576.jpg
Quote #2
"KUE's distribution of property (other than cash) to a Partner generally will not be taxable to the Partner unless the property is a 'marketable security'"Source
HOUSE_OVERSIGHT_024576.jpg
Quote #3
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