Epstein Secrets

ion 1256 Contracts are held to hedge property which would generate ordinary loss if sold at a loss. In addition, because each of the Partnership and the Master Fund is engaged in a trade or business as a trader in commodities, if such Section 1256 Contract is considered a commodity, the income and loss from suc

HUBUS133 Alpha Group Capital than for certain "safe harbor" modifications specified in Treasury Regulations, the determination of whether a modification is "significant" is based on all of the facts and circumstances. Therefore, it is possible that the Se

who is an individual will not be able to deduct losses from other "passive activities" against his or her share of income of the Partnership. Since the Master Fund may invest in the securities of foreign issuers, the Partnership's income may be subject to foreign income taxes, including withholding taxes. A Lim

is reasonable, there can be no assurance that the IRS will accept the method of computation utilized by the Partnership. The IRS has released final Treasury Regulations expanding previously existing information reporting, record maintenance and investor list maintenance requirements with respect to certain "tax she

who is an individual will not be able to deduct losses from other "passive activities" against his or her share of income of the Partnership. Since the Master Fund may invest in the securities of foreign issuers, the Partnership's income may be subject to foreign income taxes, including withholding taxes. A Lim

is reasonable, there can be no assurance that the IRS will accept the method of computation utilized by the Partnership. The IRS has released final Treasury Regulations expanding previously existing information reporting, record maintenance and investor list maintenance requirements with respect to certain "tax she