l income tax purposes (should be distinguishable from the preferred equity that was reviewed and held to be debt for federal income tax purposes in Castle Harbor . 3 104773603 v10 EFTA00582849

fectively subject to estate tax. 7. Impact on the tax effects if the preferred interests were treated as debt for federal income tax purposes (ala Castle Harbor decision). 8. Would the tax effects on basis/step up at death/estate tax considerations/non-tax considerations be the same if the SPV/principals ac

al income tax purposes (should be distinguishable from thepreferred equity that was reviewed and held to be debt for federal income tax purposes in Castle Harbor 3 104773603 14.1,0 EFTA_R1_00451004 EFTA01969638 AGSH&F DISCUSSION DRAFT JUNE 19.2013 Calculation of thc value of thc preferred interests hel