Epstein Secrets

which presumably becomes a disregarded entity. A final note. It is worth contrasting the holdings of these two opinions with the actual language of New York's estate tax law and its constitution. As noted above, the tax law (§ 960 of Article 26) says that estate tax applies to a non-resident decedent's tr

for example, that non- resident Mom and Dad are the two members of the LLC that owns a New York condo; will this structure insulate the condo from New York estate tax when the first of them dies? Arguably yes, although the New York tax could be moot at that point if the deceased spouse's LLC interest s

elected to be treated as a corporation, it is disregarded for income tax purposes, and is effectively treated as "one" with its owner/member. • A Subchapter S corporation is a "pass-through" entity that passes through its income to shareholders, and is therefore not subject to corporate-level income tax.

nds to or upon U.S. Cellular in respect of all or any series of debt securities and such Indenture may be served, which must be located in New York, New York or be the principal office of U.S. Cellular; • to provide for the payment by U.S. Cellular of additional amounts in respect of certain taxes impose

ir securities holdings, individual retirement accounts or qualified pension plans or investors in pass-through entities, including partnerships and Subchapter S corporations that invest in the Notes. In addition, this discussion is limited to holders who are the initial purchasers of the Notes at their orig

New York treats Mom as if she were a New York resident, and her taxable estate — the $5.34 million credit shelter trust for Dad — exceeds New York's $1 million exclusion, thereby triggering hypothetical New York estate tax of $431,600. Since Mom's interest in the condo represents 5% of her estate

elected to be treated as a corporation, it is disregarded for income tax purposes, and is effectively treated as -one" with its owner/member. • A Subchapter S corporation is a "pass-through" entity that passes through its income to shareholders, and is therefore not subject to corporate-level income tax.