""Holder of Income Notes"" — Epstein Files Search

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EFTA01092343Set 9

2007-01-17141p86,219w

Treatment of U.S. Holders of the Senior Notes 78 Tax Treatment of U.S. Holders of Income Notes 79 Tax Treatment of Tax-Exempt U.S. Holders 81 Tax Treatment ... Collateral have been made, including payments to the Holders of the Senior Notes. Holders of Income Notes are not entitled to the return of a stated principal amount ... expected to be a passive foreign investment company, which means that a U.S. holder of Income Notes (other than a person or entity treated as a U.S. shareholder

https://www.justice.gov/epstein/files/DataSet%209/EFTA01092343.pdf

EFTA01376112Set 10

rule permitting the deferral of tax on undistributed earnings would not apply. A holder of Income Notes that is a U.S. Shareholder of the Issuer subject to the CFC rules ... corporation that is treated as equity for U.S. federal income tax purposes. U.S. holders of Income Notes could be treated as holding an indirect investment in a PFIC

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01376112.pdf

EFTA01365231Set 10

Collateral have been made. including payments to the Holders of the Senior Notes. Holders of Income Notes are not entitled to the return of a stated principal amount

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01365231.pdf

EFTA01376070Set 10

Collateral have been made. including payments to the Holders of the Senior Notes. Holders of Income Notes are not entitled to the return of a stated principal amount

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01376070.pdf

EFTA01365292Set 10

phantom" income. The Issuer will provide, upon request, all information that a U.S. holder of Income Notes making a QEF election is required to obtain for U.S. federal income ... investing in a PFIC and the desirability of making the QEF election. U.S. HOLDERS OF INCOME NOTES SHOULD CONSIDER CAREFULLY WHETHER TO MAKE A QEF ELECTION WITH RESPECT

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01365292.pdf

EFTA01376111Set 10

phantom" income. The Issuer will provide, upon request, all information that a U.S. holder of Income Notes making a QEF election is required to obtain for U.S. federal income ... investing in a PFIC and the desirability of making the QEF election. U.S. HOLDERS OF INCOME NOTES SHOULD CONSIDER CAREFULLY WHETHER TO MAKE A QEF ELECTION WITH RESPECT

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01376111.pdf

EFTA01365284Set 10

respective Affiliates or any entity related to any of them or any other Holder of Income Notes. It acknowledges that none of such persons will, in any way. be responsible

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01365284.pdf

EFTA01365219Set 10

Treatment of U.S. Holders of the Senior Notes 78 Tax Treatment of U.S. Holders of Income Notes 79 Tax Treatment of Tax-Exempt U.S. Holders 81 Tax Treatment

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01365219.pdf

EFTA01376061Set 10

Treatment of U.S. Holders of the Senior Notes 78 Tax Treatment of U.S. Holders of Income Notes 79 Tax Treatment of Tax-Exempt U.S. Holders 81 Tax Treatment

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01376061.pdf

EFTA01365282Set 10

INTEREST IN THESE INCOME NOTES PREVIOUSLY TRANSFERRED TO OR HELD BY NON- PERMITTED HOLDERS OF INCOME NOTES IN ACCORDANCE WITH AND SUBJECT TO THE TERMS OF THE INDENTURE. THESE INCOME

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01365282.pdf

EFTA01365247Set 10

Principal Proceeds as an Incentive Management Fee: and 10. the remainder to the Holders of Income Notes. Except as otherwise stated, determinations to be made within the Priority of Payments

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01365247.pdf

EFTA01365233Set 10

expected to be a passive foreign investment company. which means that a U.S. holder of Income Notes (other than a person or entity treated as a U.S. shareholder

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01365233.pdf

EFTA01365258Set 10

Class D Notes remain Outstanding, and then to the Income Notes. No Holder of Income Notes shall be entitled to institute proceedings or to seek any other remedy under

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01365258.pdf

EFTA01376089Set 10

Class D Notes remain Outstanding, and then to the Income Notes. No Holder of Income Notes shall be entitled to institute proceedings or to seek any other remedy under

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01376089.pdf

EFTA01376448Set 10

Principal Proceeds as an Incentive Management Fee; and (J) the remainder to the Holders of Income Notes. (b) If on any Payment Date the amount available in the Payment Account

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01376448.pdf

EFTA01376419Set 10

Notwithstanding anything to the contrary herein, no Holder of Income Notes shall be entitled to institute Proceedings or seek any other remedy hereunder unless all of the Senior Notes have

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01376419.pdf

EFTA01365674Set 10

Notwithstanding anything to the contrary herein, no Holder of Income Notes shall be entitled to institute Proceedings or seek any other remedy hereunder unless all of the Senior Notes have

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01365674.pdf

EFTA01376431Set 10

return. (f) The Issuer will provide, upon the written request of a Holder of Income Notes certifying that it is such a Holder, any information that such Holder reasonably requests

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01376431.pdf

Corpus: 1990-03-17 – 2025-12-01

January 2007

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Results by Dataset18 total

Set 9

1

Set 10

17