EFTA02465115

From: Sent: To: Subject: jeffrey E. <[email protected]> Monday, May 2, 2016 4:00 PM Melanie Spinella Fwd: brads going to present me his ideas on presentation. =? . re tra fire drill review. needs a =oal.. not merely see what categories things fall into . =amendments should be tailored for benefit. not just clarified. <=iv> Forwarded messa e F=om: Brad Wechsler =ate: Mon, May 2, 2016 at 11:53 AM Subject: Re: To: "[email protected]" <[email protected]> Jeffrey-let me give you the top-line and others =an fill in as necessary on the issues noted below and progress. 1. 8RH k: key point is that both apo and pw have indicated that their read =s that no two principals can take an action that is prejudicial to the thi=ds estate. This is key but must be socialized with marc and josh (by john =) and then be clearly reflected. A. Of lesser importance, wendy is trying to push thru the 754 election at a= professionals, make certain an estate has access to "information rig=ts", see if the three partners want mfn investment rights to continue=past death and fix some language "clarifications. Wendy is quarterbacking this and timing is apo dependent which means likely=to be a process. On some none "fire-drill" issues which are nonetheless quite impt= pls note: 2. People are comfortable with TRA transfer with respect to 2007 stock sale= and, I believe, are expressing "sufficient comfort" with respec= to a TRA transfer for future sales. There are definitely imbedded issues =ith respect to "completed gifts" and creating a separation from BRH without causing tax effects. Nonetheless, it appears=we'll come out ok. 3. TIC still appears somewhat problematic to alan or said differently: I do='t believe AH is comfortable with "nominal ownership and exclusiv= use". 4. We (and you) now know that a clat works and we can have an ultimate bene=iciary as the foundation, a clat or both. You, leon and alan have to decid= whether you want to "hard wire" the clat into the planning coda= (can do one that has some built in flexibility) or defer to a later date. 5. By later today or tomorrow I shld be able to show you "my take"= on how to simply present the grat back-up. Obviously feel free to reach out to any on and all for more detail on the a=ove. B EFTA_R1_01572839 EFTA02465115 From: Jeffrey E. [mailto:[email protected] <mailto:jeevacation@g=ail.com> Sent: Monday, May 02, 2016 06:20 AM To: 1 Brad Wechsler Subject: where are we with re do of fire drill docs 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 www.imax.com <http://www.imax.c=m> IMAX' is a registered trademark of IMAX Corporation. IMPORTANT NOTICE Information contained in this e-mail correspondence and any attachments is =onfidential information intended only for the use of the individual or ent=ty named above. Any reader of this message who is not the intended recipient of this corres=ondence is hereby notified that any dissemination, distribution, copying or communication of the contents of this correspondence is strictly prohibi=ed. If this e-mail was not addressed to you , please immediately notify us=br> by phone in Canada at (905) 403.6500 <tel:%28905%29%20403-6500> (collect calls will be accepted= or by email at [email protected] <mailto:[email protected]> and delete and destroy this correspondence inadvertently sent to you. Thank you please note =he information contained in this communication is confidential, may be =ttorney-client privileged, may constitute inside information, and is in=ended only for the use of the addressee. It is the property of JEEUnauthorized use, disclosure or copying of this communication or any p=rt thereof is strictly prohibited and may be unlawful. If you have rece=ved this communication in error, please notify us immediately by ret=rn e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication an= all copies thereof, including all attachments. copyright -all rights r=served 2 EFTA_R1_01572840 EFTA02465116