EFTA01758370

understood, but is the calculation every year that of an i=stallment obligation or does it reflect the specific character of the t=x saved by apo? ie, the mix of tax savings or the mix of original sale =/div> On Wed, May 1=, 2013 at 8:40 AM, Fenn, Patrick mailto > wrot=: Gain on sale would be a combination of capital gain and ordinary income. Th= sale of the installment obligation is considered to be an amount realized=on the sale of the property giving rise to the installment obligation. So = sale of the TRA would be taxed as part ordinary and part capital gain in the same proportion as applies t= the original sale of the partnership interest that gave rise to the insta=lment sale. Will get to Vincent today about the calculation. From: Jeffrey Epstein (mailto:[email protected] <mailto:[email protected]> Sent: Wednesday, May 15, 2013 08:32 AM To: Fenn, Patrick Subject: IF i understood you correctly, I assume the sale or exchan=e of the the remaining tra payments would be considered disposition of =nstallment debt so mostly Itcg. After vincent calculates the amount, we=should talk. The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved IRS Circular 230 Notice Requirement: This communication is not given in the=form of a covered opinion, within the meaning of Circular 230 issued by th= United States Secretary of the Treasury. Thus, we are required to inform =ou that you cannot rely upon any tax advice contained in this communicatio= for the purpose of avoiding United States federal tax penalties. In addit=on, any tax advice contained in this communication may not be used to prom=te, market or recommend a transaction to another party. EFTA_R1_00061230 EFTA01758370 The information contained in this e-mail message is intended only for the p=rsonal and confidential use of the recipient(s) named above. If you have r=ceived this communication in error, please notify us immediately by e-mail= and delete the original message. The information contained in this c=mmunication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the a=dressee. It is the property of Jeffrey Epstein Unauthorized use, di=closure or copying of this communication or any part thereof is strictl= prohibited and may be unlawful. If you have received this communication in error, p=ease notify us immediately by return e-mail or by e-mail to [email protected], =nd destroy this communication and all copies thereof, including all attachm=nts. copyright -all rights reserved --047d7b4507427b496304dcc12157-- date-last-viewed 0 date-received 1368621955 flags 8590195713 remote-id 301379 2 EFTA_R1_00061231 EFTA01758371