EFTA01104587Set 9
42p20,799w
second irrevocable trust that is a U.S. trust and gives the
trustees of the U.S. trust the unrestricted right to withdraw assets from the foreign trust. This
right of withdrawal ... trust the owner of the foreign trust assets under §678, but
only after Hal's death. A trust will be treated as the owner of another trust to the extent ... trust, rather than a foreign trust, is now
deemed to own the trust assets.
Following Hal's death, if the trustees of the U.S. trust are directed to sell
https://www.justice.gov/epstein/files/DataSet%209/EFTA01104587.pdf
EFTA00812591Set 9
44p16,338w
removal,
or replacement of co-trustee, trust advisor, or trust protector.
Neither the transferor nor any other natural person who is a nonresident of the Virgin Islands nor
an entity ... more co-trustees, trust advisors, or
trust protectors, regardless of whether or not such trust advisor or trust protector is a fiduciary.
§ 1575. Service as investment trust advisor.
Any individual ... transferor's service
as trust advisor pursuant to § 1575. The transferor has only such powers and rights as are
conferred by the trust instrument. Except as permitted
https://www.justice.gov/epstein/files/DataSet%209/EFTA00812591.pdf
EFTA00803557Set 9
2017-07-0571p34,778w
trust, a completed copy of Exhibit E listing the current beneficiaries of the trust that
have, directly or indirectly, 25% or more of any interest in the trust, the senior ... other than a grantor trust). the U.S. trust (other than a ol a grantor trust dies.
grantor trust) and not the beneficiaries of the trust. Penalties
Foreign person ... Nonresident Aliens and Foreign Entitles). reasonable cause and not to willful neglect.
Nonresident alien who becomes a resident alien. Generally. only a nonresident Civil penalty for false Information with reaped
https://www.justice.gov/epstein/files/DataSet%209/EFTA00803557.pdf
EFTA00604465Set 9
2017-07-0571p34,740w
trust, a completed copy of Exhibit E listing the current beneficiaries of the trust that
have, directly or indirectly, 25% or more of any interest in the trust, the senior ... other than a grantor trust). the U.S. trust (other than a ol a grantor trust dies.
grantor trust) and not the beneficiaries of the trust. Penalties
Foreign person ... Nonresident Aliens and Foreign Entitles). reasonable cause and not to willful neglect.
Nonresident alien who becomes a resident alien. Generally. only a nonresident Civil penalty for false Information with reaped
https://www.justice.gov/epstein/files/DataSet%209/EFTA00604465.pdf
EFTA01280333Set 10
18p6,786w
FUND AND SHOULD BE CONSIDERED
WHEN PREPARING FORM 4952.
PLEASE NOTE THAT EXCEPT FOR LINES 1, 2 AND 10, NONE OF THE DISTRIBUTIVE SHARE ITEMS REPORTED ON SCHEDULE ... Loss sharing •__p_.43 9 0 ea I Is this partner a resident of California? •CYes •IZNo
(Nmership ot capital __11,22.1/1).%
J Analysis ofcrinera capital acoount Check ... Partner's State of Residence or Commercial 0tankile c1 FL
(d) Indiana Tax YVIthheici for Nonresident Partner (on W14-113)
(e) Partner's Federal Pro Rate Percentage 0, 0//581
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01280333.pdf
EFTA00986953Set 9
2014-03-275p1,564w
Pass-through entities must pay the withholding tax for all nonresident owners, with the
following exceptions:
Exception 1: Individuals who are exempt from paying federal income taxes by
reason ... Action Required
Rich, why exempt? I would find out how much the VA non-resident income is projected to be.
if immaterial..doesn't matter..
It says that ... election include:
1) A pass-through entity.
2) A Real Estate Investment Trust (REIT), except Captive REITs.
3) An Individual who is exempt from paying Federal income taxes or Virginia
https://www.justice.gov/epstein/files/DataSet%209/EFTA00986953.pdf