EFTA00726597Set 9
2007-11-147p3,391w
PREFERRED EQUITY FREEZE ENTITY: FREQUENTLY ASKED QUESTIONS
November 14, 2007
This summary answers common questions about the creation and tax considerations of
preferred freeze partnerships. Attached is a sample agreement ... Sample Freeze Agreement")
creating a freeze partnership in the form of a Delaware statutory trust ("Freeze Entity"). Unless
otherwise defined, all other capitalized terms shall have the meaning defined ... Sample
Freeze Agreement.
For more detailed discussion of the issues below, please see the summaries titled
"Preferred Equity Freeze Entity: Federal Income Tax Aspects" (referred to below as "Income
https://www.justice.gov/epstein/files/DataSet%209/EFTA00726597.pdf
EFTA00742418Set 9
2007-11-149p4,859w
Preferred Equity Freeze Entity:
Transfer Tax Aspects
November 14, 2007
This summary reviews certain U.S. federal transfer tax aspects of a freeze structure under current
law, but keep in mind ... rules may apply. This summary is based on the sample Agreement of Trust
("Sample Freeze Agreement") for a Delaware Statutory Trust ("Freeze Entity") that reflects the
basic principles ... freeze structure. Unless otherwise defined in this summary, all capitalized
terms shall have the meaning ascribed to them in the Sample Freeze Agreement.
This summary is not intended to address
https://www.justice.gov/epstein/files/DataSet%209/EFTA00742418.pdf
EFTA00617244Set 9
1990-11-0513p4,524w
EMPIRE VALUATION CONSULTANTS
CONSIDERATIONS IN THE VALUATION
OF INTERESTS IN ESTATE FREEZE ENTITIES
November 2007
350 Fifth Avenue, Suite 5513, New York, NY 10118 Phone: 212.714.0122
777 Canal View Boulevard ... Street, Suite 201, West Hartford, CT 06107 Phone: 860.233.6552
EFTA00617244
The purpose of a Freeze Entity is to lock or "freeze" the rate of appreciation in
assets that will ... substantially all of the
appreciation potential. To accomplish this, it is common that a Freeze Entity is
created with three classes of equity interests - Managing Units, Preferred Units,
and Residual
https://www.justice.gov/epstein/files/DataSet%209/EFTA00617244.pdf
EFTA01091832Set 9
2004-11-1967p15,221w
case of an earlier "cheap stock" gift,
has the attraction of definitively "freezing" value as of the date of the gift and
unconditionally shifts all post-gift appreciation ... calculation
purposes.
As in the case of early stage gifting, the effectiveness of non-freeze pre-IPO or
pre-acquisition gifting can be enhanced through the use of a family ... planning flexibility and the
opportunity for additional gift-leveraging through installment sale techniques.
B. Freeze Strategies
Not surprisingly, however, clients are seldom enamored with the prospect of
actually paying gift
https://www.justice.gov/epstein/files/DataSet%209/EFTA01091832.pdf
EFTA00611084Set 9
2011-05-019p5,219w
Preferred Partnership Freezes
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Preferred ... Partnership Freezes
They come in different flavors; and provide a menu of creative planning solutions
By N. Todd Angkatavanich & Edward A. Vergara
Preferred partnerships (Pps) are very useful and versatile ... investment vehicle. From an estate planning perspective, these
partnerships are sometimes referred to as "freeze partnerships," because they provide a structure
that enables one class of partnership interests, typically held
https://www.justice.gov/epstein/files/DataSet%209/EFTA00611084.pdf
EFTA01755021Set 10
2013-11-1338p10,594w
what could make it acceptable.
To begin with, it is worth recalling that "freeze for freeze" was
a proposal that Javier Solana, representing the European
Union, sought to produce ... talks with his Iranian counterparts
in 2007. The idea was the Iranians would freeze the
development of their nuclear program -- meaning the
enrichment of uranium and production of centrifuges ... return for the freezing of sanctions on Iran. At the time, Iran's
nuclear program had not accumulated even one bomb's worth
of material and its centrifuges numbered
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01755021.pdf
EFTA01206813Set 9
2015-04-208p3,296w
Selection Vectors and three agent responses, as a constrained-contested space.
Selection
Vectors
fight
freeze * (niche/agency
flight
Figure B: Classic effects between selection forces and agent responses, equally labeled stabilizing ... Stanford University (March 2011).
20 April 2015, M. Abundis ( 1): Logical Contours.
EFTA01206813
and freeze, but could be equally named adapt, escape, and succumb (Figure A). This constrained-
contested schema ... demands and opportunities — defined via divisive, purifying, and directional
selection contra fight„flight, and freeze actions — or, collectively speaking: evolutionary
dynamics. This constrained-contested space exhausts all environment-agent interactions
https://www.justice.gov/epstein/files/DataSet%209/EFTA01206813.pdf
EFTA00700340Set 9
2012-10-1726p9,041w
Press, President Mahmoud Abbas indicated his
willingness to drop the longstanding demand that Israel freeze settlement
construction as a precondition to peace talks after the General Assembly
passes ... negotiations with Israel, and
give him room to drop the demand for a settlement freeze. Thus, a major
sticking point that for the last four years has stood ... Palestinians are looking for a way to bypass their demand for
a settlement freeze were first seen on September 25th, when Abbas met
with a group of Jewish leaders
https://www.justice.gov/epstein/files/DataSet%209/EFTA00700340.pdf
EFTA00603129Set 9
2010-12-234p1,796w
your records.
• Victims of identity theft also have the right to place a security freeze on their consumer reports. A
security freeze is designed to prevent credit, loans and services ... from being approved in your name
without your consent. However, a security freeze may delay your ability to obtain credit. You
may request that a security freeze be placed ... address
below. The following information should be included when requesting a security freeze: ( 1) full
name, with middle initial and any suffixes; (2) Social Security number; (3) date of birth
https://www.justice.gov/epstein/files/DataSet%209/EFTA00603129.pdf