EFTA02042877

To: From: jeffrey E. Sent Tue 9/20/2016 7:57:03 PM Subject: Fwd: legislation Remind me tomorrow Forwarded messa e From: William Blum Date: Tuesday, 20 Se Subject: legislation To: "jeffrey E." <jeevaeationasmail.com> My schedule is fairly open tomorrow. Bill William Blum I Partner SOLOMON BLUM HEVMANN LLP Nevi York, NY 10005 Tel Fax Erna, From: Jeffrey E. [mailto:ieevacation(aamail.coml Sent: Tuesday, September 20, 2016 3:11 PM To: William Blum Subject: Re: legislation lets try to talk tomorw On Tue, Sep 20, 2016 at 11:29 AM, William Blum wrote: EFTA_R1_00571509 EFTA02042877 Dear Jeff — When do you want to discuss your list of trust—related points below or any other aspects of the bill? Most of these points are already covered except principal and income and decanting. I have already drafted and added decanting provisions for the next draft, which I want to circulate in the next day or two. I am also thinking of adding the Uni form Principal and Income Act. The VI has never had this legislation and nearly every other U.S. jurisdiction does have it. I have also drafted a provision to eliminate the "Obama care tax" (formally known as the Net Investment Income Tax) with respect to USVI source interest and dividends in the future as well as some provisions to assist in enforcement of the tax with respect to past years (the tax started in 2013). Apparently, a lot of taxpayers have not been paying it arguing that it is not mirrored. I don't know if you have been paying this tax but in our view it is clearly applicable. But this also brings up again the issue of an equivalent of PR Act 22 to eliminate all taxes on VI source capital gains (at least on personal property) and other passive income to the extent allowed by the IRC. In PR this only applies to newcomers. We need to talk about this. Bill William Blum I Partner SOLOMON BLUM HEYMANN LLP New York, NY 10005 Tel Fax Email From: Jeffrey E. [mailto: eevacation(Thomail.com] Sent: Thursday, September 15, 2016 6:18 PM To: William Blum Subject: EFTA_R1_00571510 EFTA02042878 1. Quiet Trusts vs. Trusts with obligation of Trustee to disclose to beneficiaries. 2. Divided or Directed Trusts. 4. Decanting. 5. Reformation and modification. 6. Dynasty Trusts. 7. Self-settled asset protection trusts. 8. Income and principal division. please note 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 JEE 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 jeeN [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note 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 JEE 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 EFTA_R1_00571511 EFTA02042879 return e-mail or by e-mail to ice\ [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note 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 JEE 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 jeevacationegmail.com and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA_R1_00571512 EFTA02042880