HOUSE_OVERSIGHT_024575.jpg

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Extraction Summary

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People
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Organizations
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Locations
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Events
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Relationships
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Quotes

Document Information

Type: Legal/financial document (offering memorandum or prospectus)
File Size: 2.87 MB
Summary

This document is page 142 of a legal memorandum or prospectus, stamped HOUSE_OVERSIGHT_024575, detailing the U.S. federal income taxation rules for partners in an entity named KUE. It discusses 'anti-inversion legislation,' the acquisition of entities 'KLC' and 'k12', and specific valuations for LP Units ($999) and GP Shares ($1). The text outlines tax liabilities, the flow-through of taxable income, and potential IRS challenges regarding allocation provisions.

Timeline (1 events)

N/A
Acquisition of KLC and k12 by KUE
United States

Locations (1)

Location Context

Relationships (2)

KUE Acquisition KLC
acquisition of KLC and k12
KUE Acquisition k12
acquisition of KLC and k12

Key Quotes (3)

"We will treat the fair market value of each Common LP Share at $999 and the fair market value of each GP Share as $1."
Source
HOUSE_OVERSIGHT_024575.jpg
Quote #1
"KUE believes that it is not currently a publicly traded partnership and does not intend to become a publicly traded partnership within two years of this offering or the acquisition of KLC and k12."
Source
HOUSE_OVERSIGHT_024575.jpg
Quote #2
"The IRS may challenge the manner in which income, gains, losses and deductions are allocated..."
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HOUSE_OVERSIGHT_024575.jpg
Quote #3

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