EFTA02396316

From: Ada Clapp Sent: Wednesday, February 26, 2014 3:18 PM To: [email protected]; Christopher L Hurtado Cc: Eileen Alexanderson; [email protected]; Richard Joslin Subject: GRATs Hi Alan and Chris, As you know, Leon is due to receive his first annuit= payment form the APO1 GRAT No. 2 (dated December 4, 2013) on March =, 2014. Please prepare the assignment form. We w=ll let you know the cash portion of the annuity after the dividend is paid= At Rich 1's request, we would like the APO1 G=AT No. 3 to be dated March 4, 2014 ( this will align the annuity payments =or GRATs No 2 and 3). Would you please prepare a new GRAT agreement =nd assignment form. I am assuming that Leon wishes to re-GRAT the BFP interests he received from the APO1 GRAT on Janu=ry 24th and the BFP interest he will receive from the GRAT No. = on March 3rd. Jeffrey-can you confirm that my understanding is correct?=/p> Regarding valuations, Leon will require a full valua=ion report for his gift to GRAT No. 3. Since Empire does not prepare=its valuations showing the value of a 1% interest in BFP but rather the va=ue of the entire interest transferred, if Leon re-GRATs BFP interests received on both January 24th and March 3rd, GRAT No. 2 will need a separate restric=ed use valuation report (RUVR) for its in-kind distribution of the annuity=payment to Leon on March 3rd. Likewise, the APO1 GRAT will need a RUVR for the January 24th in-kind distribution. Do you agree? Thanks in advance! Ada Clapp Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022 Direct Dia Fax: 646-589-0330 1 EFTA_R1_01428395 EFTA02396316 Email: IRS Circular 230 Disclosure: Pursuant to IRS =egulations, I inform you that any tax advice contained in this communicati=n (including attachments) is not intended or written to be used, and canno= be used, by any person or entity for the purposes of (i) avoiding tax related penalties imposed by any gove=nmental tax authority, or (ii) proposing, marketing or recommending to ano=her party any transaction or matter discussed herein. I advise you t= consult with an independent tax advisor on your particular tax circumstances. This communication and any attachment is for the =ntended recipient(s) only and may contain information that is privileged, =onfidential and/or proprietary. If you are not the intended reci=ient, you are hereby notified that further dissemination of this communication and its attachments is prohibited.&nbs=; Please delete all copies of this communication and its attachments and n=tify me immediately that you have received them in error. Thank you.=nbsp; 2 EFTA_R1_01428396 EFTA02396317