EFTA01971769

To: Jeffrey Epsteileevacation mail.comj Cc: Kirschner, Elyse From: McCaffrey, Carlyn Sent Sun 5/26/2013 10:40:32 AM Subject: RE: Dear Jeffrey, The answer depends on Leon's objectives. If he's interested in selling the art and deferring tax on the gain, we could consider a Nimcrut. But his charitable deduction would likely be limited to his basis. If he's interested in obtaining a full income tax deduction, and is not looking to retain any economic interest in the art, we could consider outright gifts to one or more museums to a private operating foundation controlled by him. In each case, the donee would agree to use the donated art in furtherance of its charitable purpose. I'll be back in the US next Friday if you'd like to discuss this topic. Best Carlyn Carlyn S. McCaffrey P McDermott Will & Emery LLP I New York, NY 10173 I www.mwe.com From: Jeffrey Epstein [mailto:[email protected]] Sent: Saturday, May 25, 2013 3:05 PM To: McCaffrey, Carlyn Subject: what structure do you like now for leon giving some of his art to charity, nimcrut? etc? EFTA_R1_00454725 EFTA01971769 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 jeevacation®gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved iHe******iHe*********** **Air It Illtht*********** ****tifelk IRS Circular 230 Disclosure: To comply with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained herein (including any attachments), unless specifically stated otherwise, is not intended or written to be used, and cannot be used, for the purposes of (i) avoiding penalties under the Internal Revenue Code or (I) promoting, marketing or recommending to another party any transaction or matter herein. This message is a PRIVILEGED AND CONFIDENTIAL communication. This message and all attachments are a private communication sent by a law firm and may be confidential or protected by privilege. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of the information contained in or attached to this message is strictly prohibited. Please notify the sender of the delivery error by replying to this message, and then delete it from your system. Thank you. Please visit httrd/www.mwe.com/ for more information about our Firm. EFTA_R1_00454720 EFTA01971770