Epstein Secrets

o controlled group liability if the funds together held 80% or more of the portfolio company in question (together with the 2013 Sun Capital Case, the "Sun Capital Cases"). Although the extent of the impact of the holdings in the Sun Capital Cases is unclear, the possibility of trade or business characterization re

nd invests (even if, with respect to such partnership, the Underlying Fund was not a partner of the partnership during the tax year under audit). United States Tax Reporting by Limited Partners that are Owners of Non-U.S. Entities. United States tax rules impose information reporting requirements on U.S. persons that own, either directly

o controlled group liability if the funds together held 80% or more of the portfolio company in question (together with the 2013 Sun Capital Case, the "Sun Capital Cases"). Although the extent of the impact of the holdings in the Sun Capital Cases is unclear, the possibility of trade or business characterization re

nd invests (even if, with respect to such partnership, the Underlying Fund was not a partner of the partnership during the tax year under audit). United States Tax Reporting by Limited Partners that are Owners of Non-U.S. Entities. United States tax rules impose information reporting requirements on U.S. persons that own, either directly

o controlled group liability if the funds together held 80% or more of the portfolio company in question (together with the 2013 Sun Capital Case, the "Sun Capital Cases"). Although the extent of the impact of the holdings in the Sun Capital Cases is unclear, the possibility of trade or business characterization re

nd invests (even if, with respect to such partnership, the Underlying Fund was not a partner of the partnership during the tax year under audit). United States Tax Reporting by Limited Partners that are Owners of Non-U.S. Entities. United States tax rules impose information reporting requirements on U.S. persons that own, either directly

o controlled group liability if the funds together held 80% or more of the portfolio company in question (together with the 2013 Sun Capital Case, the "Sun Capital Cases"). Although the extent of the impact of the holdings in the Sun Capital Cases is unclear, the possibility of trade or business characterization re

nd invests (even if, with respect to such partnership, the Underlying Fund was not a partner of the partnership during the tax year under audit). United States Tax Reporting by Limited Partners that are Owners of Non-U.S. Entities. United States tax rules impose information reporting requirements on U.S. persons that own, either directly

o controlled group liability if the funds together held 80% or more of the portfolio company in question (together with the 2013 Sun Capital Case, the "Sun Capital Cases"). Although the extent of the impact of the holdings in the Sun Capital Cases is unclear, the possibility of trade or business characterization re

nd invests (even if, with respect to such partnership, the Underlying Fund was not a partner of the partnership during the tax year under audit). United States Tax Reporting by Limited Partners that are Owners of Non-U.S. Entities. United States tax rules impose information reporting requirements on U.S. persons that own, either directly