EFTA02366582

From: Barry J. Cohen Sent: Wednesday, September 20, 2017 8:43 PM To: Jeffrey E. Cc: Melanie Spinella ([email protected]); Brad Wechsler Subject: Re: EY audit experience Yes. We have all of their comments. I hope to circulate shortly. = Sent from my iPhone On Sep 20, 2017, at 3:54 PM, jeffrey E. <[email protected] <mailto:jeevacation@g=ail.com» wrote: very talented , question. has any=of them thoroughly reviewed the draft return , audits=/u> 7 at 3:38 PM, Barry!. Cohen =span dir="ltr" » wrote: Here is the summary we have on audit experience of o=r EY team. John Cook —= Partner PCS • Significant number of Federal=compliance audits (line by line) • Federal audits on:<=u> =om " At-Risk Limitations & basis • Schedule Cs • Charitable contribution a=d investment interest expense tracing • Gift tax audits • Significant number of NYS and CT &=8211; Statutory residency, domicile and income allocation </=pan> David Kirk=; Partner — National Tax PCS • About 50% of the a=dits are Global High Wealth • Most of the matters involve=treatment of pass-through items on the 1040s — passive loss, at- risk= interest tracing and SE tax EFTA_R1_01363678 EFTA02366582 </=pan> Elda Di Re=; Partner — National Tax PCS • S Gift Tax Audits=/u> • 6 Federal compliance audits (audit of each line of return)=u> • Dozens of regular 1040 audits </=pan> Greg Rosica R=1; Partner Tax Significant experience=representing clients in Federal and state (NY, NJ, CT, GA, CA) audits incl=ding: - Complex financial tr=nsactions (distressed debt, related party transactions) involving individu=ls and their pass through entities - Audits of passive v =ctive status - Support for business=use of assets (real estate, airplanes, yachts, art, equestrian)<=u> - Investment v trade o= business classification (cap gain v ordinary, developer v investor) - Equity v debt treatm=nt in real estate transactions </=pan> Mitchell Kops &#=211; Principal — National ITS Some audit experience =t Withers including: Private plane Foreign Tax credit/deduction matter </=pan> Joseph Fuschetto=— Executive Director — PCS s • Federal =udits of Schedule Cs • Federal Audits of Schedule Ec; passive v active, at-risk • Multiple gift tax audits=/u> • NYS residency and income allocation audits=/li> </=pan> Surya Shivakumar &#=211; Senior Manager — PCS 2 EFTA_R1_01363679 EFTA02366583 NJ audits R=1; full substantiation of all lines and adjustments NYS=residency & income allocation audits Barry J. Cohen = I Elysium Management,=LLC I 445 Park Avenue Suite 1401 <https://maps.google.com/?q=445+Park=#43;Avenue+Suite+1401%0D+New+York,+NY+10022&en=ry=gmail&source=g> New York, NY 10022 chttps://maps.google.com/?q=445+Park=#43;Avenue+Suite+1401%0D+New+York,+NY+10022&en=ry=gmail&source=g> 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 [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 3 EFTA_R1_01363680 EFTA02366584