EFTA02451067

From: jeffrey E. <[email protected]> Sent: Tuesday, September 20, 2016 7:11 PM To: William Blum Subject: Re: legislation lets try to talk tomorw When do you want to discus= your list of trust—related points below or any other aspects of t=e bill? Most of these points are already covered except principal an= income and decanting. I have already drafted and added decanting pr=visions for the next draft, which I want to circulate in the next day or t=o. I am also thinking =f adding the Uniform Principal and Income Act. The VI has never had this l=gislation and nearly every other U.S. jurisdiction does have it.=/u> I have also drafted a provision to elim=nate the "Obama care tax" (formally known as the Net Inves=ment 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 o= taxpayers have not been paying it arguing that it is not mirrored. = 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 eq=ivalent 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 t=lk about this. Bill William Blum I Partner<=> 40 Wall Street, 35th floor New York, N= 10005 Tel Fax :=/td > =/11> 1 EFTA_R1_01550276 EFTA02451067 Email <mailto From: jeffrey E. [mai=to:jeevacation@=mail.com <mailto:[email protected]> I Sent: Thursday, September 15, 2016 6:18 PM =o: William Blum Subject: 1.=C2 Quie= Trusts vs. Trusts with obligation of Trustee to disclose to beneficiaries= 2. <=span>Divided or Directed Trusts.<=> 4. =AO Decanting.=/p> 5. Reformation and modification. 6.=C2 Dyna=ty Trusts. 7.=span style="font-size:7.0pt;color:#1f497d"> =AO Self-settled asset protection t=usts. 8. =C2 Income and princ=pal division. <= class="MsoNormal"> please not= The information contained in=this communication is confidential, may be attorney-client privileged, =ay constitute inside information, and is intended only for the use o= the addressee. It is the property of JEE Unauthorized use, disclosu=e or copying of this communication or any part thereof is strictly proh=bited and may be unlawful. If you have received this communication i= error, please notify us immediately by return e-mail or by e-mail to <= href="mailto:[email protected]" target="_blank">jeevacation@gmail=com, and destroy this communication and all copies thereof, incl=ding all attachments. copyright -all rights reserved =div dir="ltr"> please note =div>The information contained in this communication is confidential, ma= be attorney-client privileged, may constitute inside information, and =s intended only for the use of the addressee. It is the property of =EE Unauthorized use, disclosure or copying of this communication or =ny part thereof is strictly prohibited and may be unlawful. If you have=received this communication in error, please notify us immediately byreturn e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communicatio= and all copies thereof, including all attachments. copyright -all righ=s reserved 2 EFTA_R1_01550277 EFTA02451068