EFTA01451895Dataset 10
1p593w
…Income recognized by U.S. Holders that are U.S. Tax-Exempt Investors is generally exempt from U.S. federal income tax except to the extent of the entity's UBTI. UBTI is defined generally as income from a trade or business regularly carried on by a tax-exempt entity that is unrelated to its exempt purpose. Dividends, interest and, with certain exceptions, gains or losses from the sale, exchange or other disposition of property are generally excluded from UBTI…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01451895.pdf
EFTA01454373Dataset 10
1p497w
inclusion of the PPVA in the estate. To the extent paid to a tax-exempt entity, the investment income and gains within a PPVA will not be subject to income tax. FACTS For purposes of this opinion, you have represented the following facts are true with respect to the PPVA: Under the terms of a PPVA, an issuer of the PPVA will agree to make a series of payments to an annuitant over time, beginning no later than when the…
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01454373.pdf