HOUSE_OVERSIGHT_024574.jpg
3.11 MB
Extraction Summary
1
People
3
Organizations
2
Locations
0
Events
1
Relationships
3
Quotes
Document Information
Type:
Financial disclosure / offering memorandum (excerpt)
File Size:
3.11 MB
Summary
This document page (Bates stamp HOUSE_OVERSIGHT_024574) is an excerpt from a financial offering memorandum detailing the U.S. federal income tax considerations for investing in an entity identified as 'KUE.' It defines 'U.S. Person' for tax purposes and asserts KUE's belief that it functions as a partnership, meaning it incurs no federal income tax liability itself, though it notes that legal counsel has not rendered a formal opinion on these tax consequences. The text also outlines 'anti-inversion legislation' regarding non-U.S. corporations treated as U.S. corporations.
People (1)
| Name | Role | Context |
|---|---|---|
| Secretary of Treasury | Government Official |
Mentioned in the context of regulatory authority over anti-inversion legislation.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| KUE |
The entity issuing the Limited Partnership Units; stated to be classified as a partnership for tax purposes.
|
|
| IRS |
Internal Revenue Service; mentioned regarding tax rulings and potential assertions against KUE's tax positions.
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|
| House Oversight Committee |
Implied by the Bates stamp 'HOUSE_OVERSIGHT_024574'.
|
Locations (2)
| Location | Context |
|---|---|
|
Jurisdiction for tax laws.
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|
|
Mentioned in the definition of U.S. Person/State organization.
|
Relationships (1)
References to 'Limited Partner of KUE' and 'Common LP Units'.
Key Quotes (3)
"KUE believes that it should be classified as a partnership for United States federal income tax purposes."Source
HOUSE_OVERSIGHT_024574.jpg
Quote #1
"Counsel to KUE has not rendered any legal opinion regarding any tax consequences relating to KUE or an investment in KUE."Source
HOUSE_OVERSIGHT_024574.jpg
Quote #2
"No assurance can be given that the IRS would not assert, or that a court would not sustain, a position contrary to any of the positions taken by KUE as set forth below."Source
HOUSE_OVERSIGHT_024574.jpg
Quote #3
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