EFTA01956015

To: Melanie SpineIla From: Jeffrey Epstein Sent Sun 9/22/2013 1:48:40 PM With due respect, I think a freeze partnership is far less complex than derivatives. The Code and regulations provide a roadmap of how to structure a freeze partnership. (Please identify the complex accounting rules that give you pause.) Further, we can unwind in the future. Derivatives, in my view, raise gift and estate tax concerns under 2703 and corporate law issues. And GRATs, while very effective, could lead to the very same concerns we faced earlier: Leon's lost income flow and increasing promissory notes. Alan S. Halperin I Partner From: "Jeffrey Epstein" [email protected] Sent: 09/22/2013 09:25 AM AST To: Alan Halperin Subject: Re: clever,--- I am hesitant to have a partnersip with a fixed future and extremely complex accounting and rules. There is a time component to the structures. I am also not familar with the sec laws that might apply. with regard the exchange of pro note for the art. I am attempting to make a distinction between the owner of the trust and the owner of the consideration. On Sun, Sep 22, 2013 at 9:15 AM, Alan S Halperin wrote: Will doL.Anitolease send nrieyourflua, treeie art nershi ) in light of a na . t. lh .ness to have art tied u in trust EFTA_R1_00426590 EFTA01956015 From: "Jeffrey Epstein" [[email protected]] Sent: 09/22/2013 07:26 AM AST To: Alan Halperin; "Ada Clapp" my argument is that leon is owner for fed income tax purposed of the promissory note, he owns the consideration. and substituties the art. It cannot be recognized for sales taz as he owns the same consideration before and after. its not that there is no consideration it is the ownsership of that consideration did not change. *********************************************************** 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 jeevacationOgmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA_R1_00428591 EFTA01956016