EFTA01788031

From: Kirschner, Elyse jugnign Sent: Monday, April 8, 2013 10:45 PM To: Thomas Turrin; Ada Clapp Cc: Eileen Alexanderson; Jeffrey Epstein Subject: RE: Black Family 2012 Gift Tax Reporting Obligations This is fine with me. c=p> Elyse G. Kirschner</=> I Partner McDermott Will & Emery LLP 340 Madison Avenue, New York, NY 10s <mailto:%[email protected]> &nb=p; I <http://www.mwe.com> From: Thomas T=rrin [mailto: Sent: Monday, April 08, 2013 6:28 PM To: Ada Clapp; Kirschner, Elyse Cc: Eileen Alexanderson; Jeffrey Epstein Subject: RE: Black Family 2012 Gift Tax Reporting Obligations<frp> Ada, I agree with you on makin= affirmative allocations of GST. We have always make affir=ative allocations of gst with all relevant details. The gift tax returns will¾ on extension. I will send you the drafts of the returns whe= ready. <=p> Best,</=> Tom <=p> <=p> THOMAS TURRIN, CPA<=o:p> Partner 1 EFTA_R1_00112002 EFTA01788031 Raich Ende Malter & Co. LLP 1375 Broadway New York, New York 100=8 (ext 404)=o:p> (Direct =ine) (Fax) (Cell) Email: Website: www.rem-co.com <http://www.rem-co.com> <=p> <=p> <=p> From: Ada Clap= [mailto:Mila Sent: Monday, April 08, 2013 6:19 PM To: Elyse G. Kirschner; Thomas Turrin Cc: Eileen Alexanderson; Jeffrey Epstein Subject: Black Family 2012 Gift Tax Reporting Obligations=/span> Hi Elyse and Tom, I wanted to follow up with you regarding the need to=report the gifts each of Debra, Ben, Josh, Alex and Victoria made to new t=usts they each created in 2012, as outlined in Elyse's attached memorandum= The memorandum implies that the family members will rely on the automatic allocation rules under the Treas=ry regulations for the allocation of GST exemption to their gifts. M= preference is to make an affirmative allocation of GST exemption on the g=ft tax return reporting the gift, where that is the intention, rather than relying upon the automatic allocation r=les. Not only is that the "safer" route, but it avoids con=usion later as to how much GST exemption was used by an individual, as you=have created a record for all involved to refer back to. If you elect to rely on the automatic allocation rul=s, would Elyse kindly confirm that the rules will apply to allocate =ST exemption to 100% of each family member's 2012 gift (e.g., that they ar= indirect skips to "GST trusts" under the regs) . 2 EFTA_R1_00112003 EFTA01788032 If instead, the gift tax returns will make affirmative =llocations of each family member's GST exemption, I would like the opportu=ity to review the allocation language. Thanks in advance for your response. Best regards, Ada Clapp Black F=mily Partners go Apollo Management 9 W 57th Street New York NY 10019 phone: email: almisigelgi <mailto: > <=p> IRS Circular 230 Discl=sure: Pursuant to IRS regulatio=s, I inform you that any tax advice contained in this communication (inclu=ing attachments) is not intended or written to be used, and cannot be used by any person or entity for the purpose of (i) avoiding=tax related penalties imposed by any governmental tax authority, or (ii) p=omoting, marketing or recommending to another party any transaction or mat=er discussed herein. I advise you to consult with an independent tax advisor on your particular tax circumst=nces. This communication, and a=y attachment, is for the intended recipient(s) only and may contain inform=tion that is privileged, confidential and/or proprietary If you are not the intended recipient, you are hereby notified that =urther dissemination of this communication and its attachments is prohibit=d. 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Please notify the seÞr of the delivery error by replying to this message, and then delete it =rom your system. Thank you. Please visit http://www.mwe.com/ for more information about our Firm. 4 EFTA_R1_00112005 EFTA01788034