EFTA02557654

From: Barry J. Cohen Sent: Wednesday, Decem er 27, 2017 3:13 PM To: Jeffrey E. Subject: Short answers to some questions--PRIVILEGED AND CONFIDENTIAL Boat. BJAV (foreign co.) sells boat at = loss in 2018. BJAV is then liquidated resulting in a loss to its do=estic owner. Plane. Even if we get around the domest=c flights issue, we don't have nearly enough passive income to use t=e 100% depreciation expense. Foreign entities. Agree with you that t=is will be an IRS focus, but think it will be more 2019-2021.</=> Dealer. Doing research on income tax im=lications of trade ins. \Barry J. Cohen&nbs=; President and Speci=l Counsel Elysium Management,=LLC 445 Park Avenue Suite 1401 New York, NY 10022&=bsp; &n=sp; 1 EFTA_R1_01716858 EFTA02557654