HOUSE_OVERSIGHT_026589.jpg
2.63 MB
Extraction Summary
1
People
2
Organizations
0
Locations
1
Events
0
Relationships
3
Quotes
Document Information
Type:
Legal/tax analysis memorandum
File Size:
2.63 MB
Summary
This document is a page from a legal or tax analysis memorandum, likely produced during a House Oversight investigation (as indicated by the Bates stamp). It details technical tax regulations regarding Disregarded Entities (DREs), Single Member LLCs (SMLLCs), and Grantor Trusts. Specifically, it discusses the 'economic risk of loss' in partnership debts, the use of DREs to manipulate debt basis, and state-level tax treatments. While no specific Epstein transactions are detailed on this page, the content describes the types of complex financial structures and tax avoidance strategies often associated with his financial network.
People (1)
| Name | Role | Context |
|---|---|---|
| Rothstein | Litigant |
Referenced in a legal citation regarding a case before the Second Circuit Court of Appeals.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Second Circuit Court of Appeals |
Court that issued a ruling in the Rothstein case regarding grantor trusts.
|
|
| House Oversight Committee |
Indicated by the Bates stamp 'HOUSE_OVERSIGHT' at the bottom of the document.
|
Timeline (1 events)
2006-10-11
Final regulations published regarding partnership interests held through a Disregarded Entity (DRE).
Federal (US)
Key Quotes (3)
"As a result, tax planners were able to insert virtually valueless DREs as guarantors of partnership debt to secure the associated debt basis for use by the ultimate owners of the entities."Source
HOUSE_OVERSIGHT_026589.jpg
Quote #1
"Under Reg. 1.752-2(k)(1), where a partner holds his partnership interest through a DRE, the DRE's obligations are taken into account... only to the extent of the net value of the DRE..."Source
HOUSE_OVERSIGHT_026589.jpg
Quote #2
"In Rothstein, the Second Circuit Court of Appeals implicitly held that a wholly grantor trust was not disregarded for all income tax purposes..."Source
HOUSE_OVERSIGHT_026589.jpg
Quote #3
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document