EFTA02510345

From: jeffrey E. <[email protected]> Sent: Sunday, February 22, 2015 7:34 PM To: Melanie Spinella Subject: Fwd: JMWT Reorganization You tell me Forwarded message =rom: Eileen Alexanderson Date: Sunday, February 22, 2015=br>Subject: Fwd: JMWT Reorganization To: Jeffrey Epstein <[email protected]> Begin forwarded message: From: John Murphy Date: February 19, 2015 at 1:18:02 PM EST To: Richard Joslin Cc: Peter Goodwiri Subject: RE: JMWT Reorganization <javascript:_erA7B%7D,icvm ;> Hi Richard,<=u> </=pan> That was briefly discu=sed and BDO will get back to us and recommend how this will be handled. Ho=ever I believe no benefit will accrue as we will have no taxable profits t= offset this against. Once BDO get back with proposed treatment I will advise everyone and ensure we are good=to go. </=pan> Regards,=/span> </=pan> John. </=pan> From: Richard =oslin [mailtc I Sent: Thursday, February 19, 2015 2:41 PM EFTA_R1_01642024 EFTA02510345 To: John Murphy; Eileen Alexanderson Cc: Peter Goodwin Subject: RE: JMWT Reorganization Thanks</=pan> Was there any discussi=n of the PwC issue noted previously and how this liquidation might be repo=ted to UK given that interest would not be taxable in UK and interest expe=se would be deductible, ie the PwC tax avoidance scheme. I will make myself ava=lable for call with BDO Thanks</=pan> </=pan> From: John Murphy (mai=to Sent: Thursday, February 19, 2015 9:01 AM To: Eileen Alexanderson; Richard Joslin Cc: Peter Goodwin Subject: JMWT Reorganization Hi Eileen/Rich, I just wanted to give you an update on the above and=the call we had today with BDO and MacFarlanes. * *=A0 In line with MacFarlanes advice, BDO do not see any ta= issues from a UK perspective with the proposed liquidation of the three U= companies * *=A0 In relation to the loan note interest and tax treatmen= BDO initially believe that eventually this amount will be waived as we li=uidate the companies, they will investigate this further and advise how we=will treat on the tax returns • *=A0 We have engaged BDO to prepare the 2013 Tax Returns=/u> The next steps to complete the process are as follow=: • MacFarlanes will produce a document that terminates th= loan between Acquisition LLP and Midco as at 1/1/2014 (This will done as =n addendum to the current umbrella agreement) 2 EFTA_R1_01642025 EFTA02510346 * BDO will advise how we treat this from an accounting p=rspective as well as on the UK tax side, they will also advise on the inte=est treatment as well • Peter and I will work with BDO to ensure we reflect th=s transaction as part of the June 2014 statutory accounts.</=> John to speak with BDO US to get the US opinion on the=proposed liquidations (I have a meeting in calendar for Monday to go over =his, Rich if you would like to join you are more than welcome) * We will be scheduling a follow up call towards the end=of next week to ensure this progresses and is completed in a timely fashio= Once this is done we agreed to take a look at the move=ent of Press Inc and transfer pricing etc. Regards, John. <=span> John Murphy COO/CFO Phaidon Press 65 Bleecker Street</=> New York, NY 10012</=> + 212 652 5218 [email protected] <javascript:_e(%7=%7D,IcyrnE,'[email protected]);> =u> <=span> phaidon.com <http://phaidon.c=m> </=> 3 EFTA_R1_01642026 EFTA02510347 =AO please note The information contained in this communication is<=r>confidential, may be attorney-client privileged, may constitute insid= information, and is intended only for the use of the addressee. It is =he property of JEE Unauthorized use, disclosure or copying of thiscommunication or any part thereof is strictly prohibited and may be un=awful. If you have received this communication in error, please notify =s immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destro= this communication and all copies thereof, including all attachments. =opyright -all rights reserved 4 EFTA_R1_01642027 EFTA02510348