EFTA02572800

From: Jeffrey Epstein <[email protected]> Sent: Thursday, August 1, 2013 12:18 PM To: Thomas Turrin Subject: Re: FW: N624N - Plane are the pilots manuals etc 135 restricted or 91 free=? O= Wed, Jul 31, 2013 at 11:26 AM, Thomas Turrin wrote: Jeffrey,=/span> I spoke with Michael M=ndel and Pat Fenn of Akin on Friday. Eileen was also on the call. Michael Mandel is w=rking on the restructuring the plane agreements as between Rance Acquisitions, LL=, Jet Aviation, Apollo, Leon etc...Avioneta would continue as the "benef=cial owner" of Rance for =ax purposes. See Michael's comments below. The restructuring prov=des for Part 135 chartering between Apollo and Jet Aviation...in addition =o Part 135 flights for Leon's personal use, should he choose to fly Part 135=85.Flying Part 135 personally will count toward "business use" of the =ircraft for purposes of calculating percentage of use for depreciatio= purposes...(more than 50%). The proposed restructuring also gives him =he right to Part 91 for personal use. Pat Fenn of Akin is ch=cking the law with respect to the applicability of the US excise tax for A=ollo reimbursements for year 2012 and this year —</=> I expect to hear from =im today or tomorrow. I will follow up. Best, EFTA_R1_01742536 EFTA02572800 Tom THOMAS TURRIN, CPA</=> Partner Raich Ende Malter & =o. LLP From: Mandel, =ichael [r Sent: Thursday, July 25, 2013 11:10 AM To: Thomas Turrin Cc: Fenn, Patrick; Zivot, Louis; Daigle, Brian Subject: N624N <1=> Tom, we haven't shared this specif=c outline or any documents with Jet Aviation yet, but we have discussed th= concepts embodied by the listed agreements. In any event, here is our current thinking. Basically we envision five "new" docu=ents (one of which is actually an amendment of an existing agreement):<=u> 2 EFTA_R1_01742537 EFTA02572801 1. A Dry lease Agreement between 1=t and Rance Acquisitions, tic (the aircraft's registered owner) authoriz=ng Part 135 charter operations. 2. An Operating Agreement between =ance and LDB that gives LDB a non-exclusive license for Part 91 flights. 3. An Amended and Restated Aircraf= Management Agreement among Jet, Rance and LDB covering insuring, staffing= maintaining and operating the aircraft for Part 91 operations for LDB and his family for personal use.</=> 4. A Charter Services Agreement (t=ink of it as a supplement to the Dry Lease Agreement) between Jet and Apol=o that permits Apollo to charter the aircraft (for Apollo business travel). 5. A Charter Services Agreement be=ween Jet and LDB that permits LDB to charter the aircraft for business pur=oses (that may or may not include business travel).</=> This proposal is subject to your rev=ew, as well as Patrick's analysis of the structure's impact on the abi=ity to depreciate 100% of aircraft cost given the personal use arrangements. Let Patrick or me know when you would like to discuss=this further. Thanks. Michael=5. Mandel AKIN GUMP STRAUSS HAUER & FELD LLP IRS Circular 230 Notice Requirement: This communication is not given in the=form of a covered opinion, within the meaning of Circular 230 issued by th= United States Secretary of the Treasury. Thus, we are required to inform =ou that you cannot rely upon any tax advice contained in this communication for the purpose of avoiding Uni=ed States federal tax penalties. In addition, any tax advice contained in =his communication may not be used to promote, market or recommend a transa=tion to another party. The information contained in this e-mail message is intended only for the p=rsonal and confidential use of the recipient(s) named above. 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