EFTA02341478

From: Richard Joslin Sent: Tuesday, February 25, 2014 6:44 PM To: Ada Clapp Cc: Eileen Alexanderson; Jeffrey Epstein; Richard D'Agostino; Subject: RE: Decanting the 1997 trust to APO2 As I understand this decanting, the distributing trust and receiving trust =re both grantor trusts and have the same owner before and after. As such =he receiving trust is a continuation of the distributing trust, ie same ta= ID number for income tax purposes. While two assets may have negative=tax basis in 2014 (Blue Sunshine had negative tax basis a/o 12/31/2012 o= $(300K); AP Energy Partners LLC had a negative tax basis a/o 12/312012 of=$(10K) - we do not have K-1's FY 2013), the decanting should not trigger a=y gain on transfer. On a related vein, I'd like to get Ada/Alan input on not using LDB SSN for =he grantor trusts and getting EIN's and reporting annually Form 1041 with =rust letter. I would like to have annual 1041 filing for the trusts vs =o reporting other than included on 1040 directly. Original Message From: Ada Clapp Sent: Tuesday, February 25, 2014 8:33 AM To: Richard Joslin; Richard D'Agostino Cc: Eileen Alexanderson; Jeffrey Epstein Subject: Decanting the 1997 trust to APO2 We are planning to send the Decanting Notice to the beneficiaries of the 19=7 trust today. Just checking to be sure there are no tax or other issues f=r our accounting team. If so, please let me know as soon as you can. Thank=. Sent from my iPad <?xml version=.0" encoding=TF-8"?> <!DOCTYPE plist PUBLIC "-//Apple//DTD PLIST 1.0//EN" "http://www.apple.com/DTDs/PropertyList-1.0.dtd"> <plist version=.0"> <dict> <key>date-last-viewed</key> <real>0.0</real> <key>date-received</key> <real>1393353855</real> <key>flags</key> <integer>8590195713</integer> <key>gmail-label-ids</key> <array> <integer>5</integer> <integer>18</integer> </array> <key>original-mailbox</key> <string>imap://[email protected]/%5BGmail%5D/All%20Mail</string> <key>remote-id</key> <string>391901</string> </dict> </plist> EFTA_R1_01307161 EFTA02341478