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Amber Gray-Fenner explores what can happen when tax positions become part of a broader custody or divorce dispute and why clear, proactive guidance matters.

https://bit.ly/4hh6Lv7

#taxstrategy #taxplanning #taxlaw #filingjointly #divorcetax #taxcredits
Real World Ethics: What Happens When a Judge Doesn’t Understand Tax Law - Think Outside the Tax Box
We all know how messy tax returns can get when couples who used to file jointly divorce and there are children (and tax credits) involved. It’s often difficult to explain the rules surrounding Head of...
thinkoutsidethetaxbox.com
September 8, 2026 at 8:21 PM
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EFTA00239188 | EFTA00239314 FOR EXISTING INVESTOR USE ONLY In addition, these limitations may apply to certain expenses of the Master Partnership and Millennium USA, the fee to the Administrator and payments made on certain derivative instruments to the extent allocable to activities, if any, that are not part of the Master Partnership's or Millennium USA's trade or business (including investments, if any, in partnerships that are not managed by Millennium Management or its affiliates, or investments that are treated as held for investment). The consequences of these limitations will vary depending upon the particular tax situation of each taxpayer. Accordingly, noncorporate Limited Partners should consult their tax advisors with respect to the application of these limitations. A Limited Partner will not be allowed to deduct syndication expenses, including placement fees paid by such Limited Partner or Millennium USA. Any such amounts will be included in the Limited Partner's adjusted tax basis for its Interest. Application of Rules for Income and Losses from Passive Activities. The Code restricts the deductibility of losses from a "passive activity" against certain income which is not derived from a passive activity. This restriction applies to individuals, personal service corporations and certain closely held corporations. Pursuant to Temporary Regulations issued by the Treasury Department, income or loss from Millennium USA's securities investment and trading activity generally will not constitute income or loss from a passive activity. Therefore, passive losses from other sources generally could not be deducted against a Limited Partner's share of such income and gain from Millennium USA. Income or loss attributable to certain activities of Millennium USA, including investments in partnerships engaged in certain trades or businesses may constitute passive activity income or loss. Limitation on Deductibility ofNet Losses. In the case of a noncorporate taxpayer, any net business loss for any taxable year beginning during the period 2018 through 2025 may not be used to offset nonbusiness income in excess of $250,000 ($500,000 in the case of a married couple filingjointly). To the extent Millennium USA is considered to be a trader in securities, as it expects to be, any net loss from Millennium USA may, therefore, be unavailable to offset investment income earned by a Limited Partner, including investment income earned outside of Millennium USA. Any disallowed loss will carry forward and may, subject to certain limitations, be used to reduce taxable income earned by such Limited Partner in future years. Any trading losses incurred by a partnership in which Millennium USA invests will be subject to the same limitations when allocated to a noncorporate Limited Partner. Application of Basis and "At Risk" Limitations on Deductions. The amount of any loss of Millennium USA that a Limited Partner is entitled to include in its income tax return is limited to its adjusted tax basis in its Interest as of the end of Millennium USA's taxable year in which such loss occurred. Generally, a Limited Partner's adjusted tax basis for its Interest is equal to the amount paid for such Interest, increased by the sum of(i) its share ofMillennium USA's liabilities, as determined for federal income tax purposes, and (ii) its distributive share ofMillennium USA's realized income and gains, and decreased (but not below zero) by the sum of (i) distributions (including decreases in its share ofMillennium USA liabilities) made by Millennium USA to such Limited Partner and (ii) such Limited Partner's distributive share of Millennium USA's realized losses and expenses. DOC ID- 29147063.5 CONFIDENTIAL 1-51 UBSTERRAMAR00003982 EFTA00239314
April 25, 2026 at 2:41 AM