Case File
efta-02575671DOJ Data Set 11OtherEFTA02575671
Date
Unknown
Source
DOJ Data Set 11
Reference
efta-02575671
Pages
2
Persons
0
Integrity
Extracted Text (OCR)
Text extracted via OCR from the original document. May contain errors from the scanning process.
From:
Alan S Halperin
Sent:
Sunday, September 22, 2013 12:05 PM
To:
Jeffrey Epstein; Ada Clapp
Subject:
Re:
If your theory were correct, then no transaction betwee==a grantor and his grantor trust would be subject to sales tax.
But we know==hat this is not correct. NY has ruled that, if there is consideration, =here is a tax even if the trust is a
grantor =rust.
IRS Circular 230 =isclosure:
To ensure compliance with requirements imposed by the IRS, w==inform you that any U.S. federal tax advice contained
in this communicatio==(including any attachments) is not intended or written to be used, and =annot be used, for the
purpose of (i) avoiding penalties under the Interna==Revenue Code or (ii) promoting, marketing or recommending to
another party==ny transaction or matter addressed herein.
Alan S. Halperin I =artner
Paul, Weiss, Rifkind, Wharton & Garrison LLP
1285 Avenue =f the Americas I New York, NY 10019-6064
(Direct Phone) ==
(Direct Fax)
From: ==/b>"Jeffrey Epstein" [email protected])
Sent: =/b>09/22/2013 07:26 AM AST
To: Alan Halperin; "Ada =lapp"
I =ww.paulweiss.com
my argument is that leon is owner for fed income tax =urposed of the promissory note, he owns the =onsideration.
and substituties the art. It cannot be =ecognized for sales taz as he owns the same consideration before and =fter. its
not that there is no consideration it is==he ownsership of that consideration did not change.
The =nformation contained in this communication is confidential, may be =ttorney-client privileged, may constitute
inside information, and is =ntended only for the use of the addressee. It is the property of Jeffrey Epstein
=br>Unauthorized use, disclosure or copying of this communication or any==art thereof is strictly prohibited and may be
unlawful. If you have =eceived this communication in error, please notify us immediately by return e-mail or==y e-mail
to [email protected] <mailto:[email protected]> , and destroy this =ommunication and all copies thereof,
including all attachments. copyright -all rights =eserved
This message is intended only for the use of the Addressee and==ay contain information that is privileged and
confidential. If you are no==the intended recipient, you are hereby notified that any dissemination of =his
EFTA_R1_01747124
EFTA02575671
communication is strictly prohibited. If you have received this =ommunication in error, please erase all copies of the
message and its =ttachments and notify us immediately.
2
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EFTA02575672
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