This document reviews U.S. federal income tax aspects of a freeze structure under current law, based on a sample Agreement of Trust for a Delaware Statutory Trust. It discusses tax implications for different types of economic units within a Freeze Entity, contributions to the Freeze Entity, investment company exceptions, liabilities, disguised sale presumption, allocations, and distributions. It also covers special rules for allocating losses, taxation of built-in gains, and liquidation implications.
documents/EFTA00742409.pdf
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