Back to Network
3
Shared Docs
3
Same-Page
8 / 3
Mentions
Document Mentions (3 shared documents)
4 mentions1 same-page
Page ?Same page
From: Richard Kahn To: Jeffrey Epstein <[email protected]> Subject: Fwd: Tax Alert: Major Tax Case on US Lending Activities of Offshore Funds Date: Wed, 15 Jul 2015 17:49:11 +0000 R
From: Richard Kahn To: Jeffrey Epstein <[email protected]> Subject: Fwd: Tax Alert:
From: Richard Kahn To: Jeffrey Epstein <[email protected]> Subject: Fwd: Ta
in courts. The last major Tax Court decision on the securities trading safe harbor rules (InverWorld Inc. v. Commissioner) was issued in 1996, and the Tax Court's rather strict interpretation of the Code at that time caused many offshore hedge funds to reconsider how to carry on their US activities to avoid U
4 mentions1 same-page
Page ?Same page
From: Paul Morris <1 To: "Jeffrey Epstein" <[email protected]> Subject: Fw: The FMV Valuation Alert - Estate of Elkins [C] Date: Thu, 18 Sep 2014 21:56:26 +0000 Importance: Normal Cla
From: Paul Morris <1 To: "Jeffrey Epstein" <[email protected]> Subject: Fw: The FMV Va
From: Paul Morris <1 To: "Jeffrey Epstein" <[email protected]> Subject: Fw: Th
pecial deference." "Second, the willing buyer/willing seller test of fair market value is ubiquitous .... We therefore owe no enhanced deference to the Tax Court's application of that test." The Tax Court issued its opinion based upon "the preponderance of the evidence. ... But, when, as here, the only evidenc
3 mentions1 same-page
Page ?Same page
cision. I am pulling up the Tax Court decision and will let you know. Alan S. Halperin Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP From: Jeffrey E. [mailto:[email protected]] Sent: Wednesday, September 17, 2014 9:07 AM To: Halperin, Alan S Subject: Re: Elkins Case what was the discount???
ul, Weiss, Rifkind, Wharton & Garrison LLP From: Jeffrey E. [mailto:[email protected]] Sent: Wednesda
d it as a fall-back position in the Tax Court and adduced expert testimony of discrete discounts for the various works. We agree in large part with the Tax Court's underlying analysis and discrete factual determinations, including its rejection of the Commissioner's zero-discount position (which holding we affi
Sponsored
Mutual Connections (8)
Entities connected to both Jeffrey Epstein and the Tax Court's
LB
Leon Black
PERSON10,461 w/ Jeffrey·2 w/ the
George Mitchell
PERSON5,938 w/ Jeffrey·2 w/ the
United States
LOCATION4,786 w/ Jeffrey·2 w/ the
Bloomberg L.P.
ORGANIZATION1,256 w/ Jeffrey·2 w/ the
WE
Weiss
PERSON1,103 w/ Jeffrey·2 w/ the
Elkins
PERSON87 w/ Jeffrey·2 w/ the
DE
Decedent
PERSON8 w/ Jeffrey·2 w/ the
Tax Court
ORGANIZATION2 w/ Jeffrey·2 w/ the