EFTA02472804

From: Brad Wechsler ‘O Sent: Thursday, February 11, 2016 2:45 PM To: Jeffrey Epstein Cc: Rick Bronstein; Melanie Spinella; John Castrucci; Joe Avantario; Richard Joslin Subject: Re: Jeffrey-some people here feel you are confusing certain items....which may or may not be true. May I suggest you organize your questions and get on the phone with rich j and then we can identify meaningful loose ends. Two things to remember: we don't control the form in which jet produces numbers and, I believe, most importantly you and I (and likely leon) agree that a simple restructure to part 91 is likely the best path. In addition--and on a separate front--we plan to scrutinize costs for potential savings. As you know we have not done this yet. Also, I'm a little unclear on what your ultimate goal is. B Sent from my Verizon Wireless BlackBerry From: jeffrey E. <[email protected]> Date: Thu, 11 Feb 2016 09:20:34 -0500 To: Brad Wechsler Cc: Richard J Bronstein Melanie Spinella ohn Castrucci ; Joe Avantario Richard Joslin Subject: Re: it says charter revenue only 312 but letter says apollo hours were 42 at 18k each hour? On Tue, Feb 9, 2016 at 6:41 PM, Brad Wechsler > wrote: MEMORANDUM ATTORNEY-CLIENT PRIVLEDGE TO: Rick Bronstein CC: John Castrucci Leon Black Joe Avantario Rich Joslin FROM: Brad Wechsler Jeffrey Epstein EFTA_R1_01584919 EFTA02472804 DATE: February 9, 2016 Leon, 1. Attached, please find the January 26th memo on the airplane which was sent to you previously. It deals with Part 91 vs. 135 and attendant costs and income tax benefits. The office feels that with respect to income tax, Part 135 is more favorable, but not significantly so, i.e., between 0 and $400K depending on use. 2. Also included are detailed operating costs. These were previously sent to Jeffrey but not previously not sent to you. 3. The final note details the FET and sales tax consequences of moving from the current structure to a simplified structure. Were we to move to a very simple Part 91 only structure you could likely save $200K/year but would have to own and operate the plane in your personal name (your insurance is sufficient, but there would be a certain lack of privacy). If you held the plane in a sole purpose LLC the aforementioned savings would disappear. If Jeffrey wants to take a deep dive, we have much detailed material and we would also suggest he speak to Rich J and our aviation attorney. 4. Bottom-line, a lot of work has been done and there is not a compelling answer, one way or another. Taking into account income tax attributes, sales tax attributes and ease of use attributes it's almost a push, though I would probably marginally favor Part 135. I believe Jeffrey favors Part 91, which in my mind, is a sufficient reason to go that route. We should discuss. Thanks 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 2 EFTA_R1_01584920 EFTA02472805 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_01584921 EFTA02472806