EFTA02519146

From: Fenn, Patrick < Sent: Monday, January 13, 2014 1:34 PM To: 'Jeffrey Epstein'; Richard Joslin Subject: RE: Hi Jeffrey. Happy N=w Year. Will look at this. As you know, the right to rec=ive the TRA payments is triggered by a taxable exchange of AOG units. = To the extent a separate asset, likely a capital asset to the extent the addition=l payments are capital. Concern is that assignment of income d=ctrine might apply if the AOG Units also are not transferred. =lso have to look at contractual restrictions — payments under TRA are paid to exchanging party. Will get back to you.</=:p> From: Jeffrey =pstein (mailto:[email protected] Sent: Sunday, January 12, 2014 6:37 AM To: Fenn, Patrick; Richard Joslin Subject: can leon sell assign or contribute =either the future tra payments or a portion thereof. . i= it a contract right? capital asset 1234 , kt~l***** **•** ******** **** ******* *•*** ******** **•** ******* ** 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 Jeffrey Epstein 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 can we IRS Circular 230 Notice Requirement: This c=mmunication is not given in the form of a covered opinion, within the mean=ng of Circular 230 issued by the United States Secretary of the Treasury. =hus, we are required to inform you that you cannot rely upon any tax advic= contained in this communication for the purpose of avoiding United States=federal tax penalties. In addition, any tax advice contained in this commu=ication may not be used to promote, market or recommend a transaction to a=other party. The information containe= in this e-mail message is intended only for the personal and confidential=use of the recipient(s) named above. If you have received this communicati=n in error, please notify us immediately by e-mail, and delete the origina= message. 1 EFTA_R1_01655178 EFTA02519146 2 EFTA_R1_01655179 EFTA02519147