EFTA00598172Set 9
2011-07-2022p9,882w
purposes of this paragraph, if a private foundation
borrows money in a particular taxable year to make expenditures for a
specific charitable educational, or other similar purpose, a qualifying
distribution ... FUNDS BORROWED BEFORE 1970.
(a) If a private foundation has borrowed money in a taxable year
beginning before January 1, 1970, or subsequently borrows money
pursuant to a written commitment ... which was binding as of the last
day of such taxable year, to make expenditures for a specific
charitable, educational, or other similar exempt purpose, if such
borrowed funds
https://www.justice.gov/epstein/files/DataSet%209/EFTA00598172.pdf
EFTA01084049Set 9
2007-07-1333p10,428w
Partnerships, and each of their direct and indirect
subsidiaries, had in effect for the Taxable Year in which the Initial Sale occurred, and will have
in effect for each Taxable ... Return, as
applicable, of APO Corp. filed with respect to Taxes of any Taxable Year.
"APO FC" means APO (FC), LLC, an Anguilla limited liability company, and any
successor thereof ... Adjustment had been made.
"Non-Stepped Up Tax Liability" means, with respect to any Taxable Year, the liability
for Taxes of APO Corp., including with respect, directly or indirectly
https://www.justice.gov/epstein/files/DataSet%209/EFTA01084049.pdf
EFTA01193903Set 9
2014-01-179p6,733w
taxpayer, or if the
method used does not clearly reflect income, the computation of taxable income shall be made under
such method as, in the opinion of the Secretary, does ... from being duplicated or
omitted to be taken into account when a taxpayer's taxable income is computed under an accounting
method different from the method used to compute taxable ... pertinent inquiry is whether the
accounting practice permanently affects the taxpayer's lifetime taxable income or merely changes the
tax year in which taxable income is reported. See Rev. Proc
https://www.justice.gov/epstein/files/DataSet%209/EFTA01193903.pdf
EFTA01289887Set 10
2015-12-31114p53,158w
Market Funds $3,411,813.92
Income and Expense Summary Current Period Year•to•Date
Taxable Non Taxable Taxable Non Taxable
Dividend Income
Equines 000 0.00 121,125.00 0.00
Money Market ... Other Secedes: FIRST IN FIRST OUT
Bond Amortization Elections:
Amortize pram ium on taxable bonds based on Constant Yield Method: Yes
Accrual market discount method for all other bond types ... OPPORTUNITIES FOR EXECUTIONS AT PRICES SUPERIOR TO THE N880. PERSH:NG ALSO REGULARLY
AS TAXABLE OR NONTAXABLE BASED ON CERTAIN INFORMATION KNOWN AS OF THE DISTRIBUTION REVIEWS REPORTS FOR QUALITY
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01289887.pdf
EFTA00598243Set 9
2008-07-3118p7,762w
Excise Taxes
IRC 4966 imposes a 20-percent excise tax on taxable distributions made by a sponsoring
organization. In addition, a 5-percent excise tax applies to a fund manager ... makes a
taxable distribution knowing that it is a taxable distribution.
Taxable distributions include any distribution by a sponsoring organization from a donor-
advised fund account if the distribution ... organizations (other than to disqualifying
supporting organizations) are not taxable distributions.
o Disqualifying supporting organizations are Type III non-functionally
integrated supporting organizations and Type I, Type II, and functionally
https://www.justice.gov/epstein/files/DataSet%209/EFTA00598243.pdf
EFTA00607666Set 9
2011-07-204p1,507w
www.gcfcccorg/giftlaw/glawprosodc.jsp?AhblD=G12003-0474...
Wednesday, July 20, 2011
GiftLaw Pro
Sec. 4945 Taxes on Taxable Expenditures
Code Sections
(a) INITIAL TAXES
(b) ADDITIONAL TAXES
(c) SPECIAL RULES
(d) TAXABLE EXPENDITURE
(e) ACTIVITIES ... DEFINITIONS
(a) INITIAL TAXES
(1) ON THE FOUNDATION
There is hereby imposed on each taxable expenditure (as defined in subsection (d)) a tax equal to
20 percent of the amount ... foundation manager to the making of an
expenditure, knowing that it is a taxable expenditure, a tax equal to 5 percent of the amount
thereof, unless such agreement
https://www.justice.gov/epstein/files/DataSet%209/EFTA00607666.pdf
EFTA01139566Set 9
27p13,363w
completely repaid the amount borrowed (including interest) before the start of the
taxable year.' Deemed ownership will not occur, however, if the loan provides for both
adequate interest and adequate ... grantor's gross estate, and the
exchange of assets is not a taxable event.24 Since those high-basis assets have the same value
23 Kuno S. Bell, Use Defective Grantor ... view. In
Revenue Ruling 81-6,29 the Service concluded that a beneficiary was taxable under § 678(a)
because the beneficiary held a Crummey power, even though the beneficiary
https://www.justice.gov/epstein/files/DataSet%209/EFTA01139566.pdf
EFTA01290563Set 10
2014-12-01161p75,966w
Market Funds 143,922,655.69
Income and Expense Summary Carrot Period Year-to-Date
Taxable Nos Taxable Taxable Noo Taxable
Dividend Income
Equities 0.00 0.00 101,836.05 0.00
Money Market ... /112114 -12/3112114
Income and Expense Summary (continued) Current Period Tear-to-Date
Taxable Non Taxable Taxable Non Taxable
Interest Income
Bond Interest 5,736.06 0.00 245,681.66 0.00
FDIC ... Elections:
Treat all interest as original issue discount COID): No
Am orOze premium on taxable bonds based on Constant Yield Method: Yes
Accrual market discount method for all other bond
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01290563.pdf
EFTA01252367Set 9
2015-11-02196p113,134w
Year to date 13) Other funds debited -300,000.00 -1,530,965.92
Taxable dividends 1,761.09 6,443 52 Funds withdrawn for investments
bought -509,697.85 -4,582,691.93
Taxable ... funds credited $507,936.76
Oat nanny Descry:mon Amount (5)
Dividend and interest income
Taxable dividends Nov2 Cwidend PUTNAM SHORT DURATION INCOME FUNDY ... Dvdend UBS SELECT PRIME INSTITUTIONAL FUND 56.89
Total taxable dividends $1,761.09
Total dividend and interest income $1.761.09
Cote Actiely Desorption Annurl (S)
Other funds debited Nov 20 Withdrawal FEDERAL
https://www.justice.gov/epstein/files/DataSet%209/EFTA01252367.pdf
EFTA01597345Set 10
2020-01-0254p31,310w
prepare,.
Closing balances $1,859.63 $1,859.63
January 2020 (1) Year to date (S)
Taxable dividends 2.48 2.48 UBS FDIC-Insured Dep Pgm Account APY
Total current year ... Tarabfe divider.* Jan 31 Dividend U8S SELECT PRIME PREFERRED FUND 2.48
SYMBOL; SPPXX
Total taxable dividends
Total dividend and interest income $2.48
Investment transactions
For more information about tne price ... with ye's' recordkeepio.
moored by law to report to tie IRS all taxable dnidenok, amounts n cash accents. Accounts that are transferred stoplemental protection do not protect against charges
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01597345.pdf
EFTA01119567Set 9
2009-06-1050p26,600w
tends to be a partnership for tax purposes.
ultimately owned by taxable individuals eligible for preferential capital gains rates. For
purposes of simplicity, this Article will refer collectively ... ruling that a profits interest was taxable upon receipt) with Campbell v. Comm., 943 F. 2d.
815 (8th Cir. 1991) (reversing a Tax Court ruling that receipt of a profits ... interest was a
taxable event). See also JCT CARRIED INTEREST REPORT. supra note 1. at 6: Weisbach.
supra note I, at 727 n.22: Leo L. Schmolka, Commentary. Taring Partnership Interests
https://www.justice.gov/epstein/files/DataSet%209/EFTA01119567.pdf
EFTA01291791Set 10
2018-12-0194p43,908w
each respective bank.
Income and Expense Summary
Oment Period Yeer4o-Dde
bustle Non Taxable Taxable Non Tar*
Dividend Income
Equities 0.00 0.00 202,00000 0.00
Interest Income
FDIC Insured Bank ... securities are disposed.
Note: In the event where we cannot easily determine the taxability of an account, we may mark the account as noncovered. However, if the account does ... Other Securities: First In First Out
BOND AMORTIZATION ELECTIONS
Amortize premium on taxable bonds based on Constant Yield Method: Yes
Accrual market discount method for all other bond types: Constant
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01291791.pdf
EFTA01274015Set 10
2015-10-0258p30,147w
Total additions $3,062.21 $21,899.64
October 2015 (51 Year to date (5) Subtractions
Taxable dividends 1,762.21 17,894.70 Professional management fees and
related services ... Taxable interest 0.00 0.48
Other funds debited 0.00 -3,275.53
Total current year $1,762.21 $17,895.18
Funds withdrawn for investments
Prior year adjustment 0.00 1,404.46 bought ... other funds credited $1,300.00
Date Actlety DeX eralen AnOunt
Dividend and interestbiome
Taxable dmclends Oct I Dvidend EATON VANCE FLOATING RATE FUND
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01274015.pdf