EFTA02581759

From: Jeffrey Epstein <[email protected]> Sent: Wednesday, February 26, 2014 5:29 PM To: Ada Clapp Cc: Alan S Halperin; Christopher L Hurtado; Eileen Alexanderson; Richard Joslin Subject: Re: GRATs let them decide . i do not want to=influence their outcome On Wed, Feb 26, 2014 at 12:46 PM, Ada Clapp <mailto » wrote: I did ask Empire about dong the valuati=ns that way and was told they did not do their valuations in this manner b=cause it did not take into account a discount associate with the percentage involved. Should we insist?<=u> Ada Clapp</=> Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022<=span> Direct Dial: <tel Fax: <tel Email: </=> IRS Circular 230 Disclosure: Pursuant to IRS regulations, I inform you that any =ax advice contained in this communication (including attachments) is not i=tended or written to be used, and cannot be used, by any person or entity for the purposes of (i) avoiding tax rela=ed penalties imposed by any governmental tax authority, or (ii) proposing,=marketing or recommending to another party any transaction or matter discu=sed herein. I advise you to consult with an independent tax advisor on your particular tax circumstances. = This communication and any attachmen= is for the intended recipient(s) only and may contain information that is=privileged, confidential and/or proprietary. If you are not the intended recipient, you are hereby notified that furthe= EFTA_R1_01758447 EFTA02581759 dissemination of this communication and its attachments is prohibited.&nb=p; Please delete all copies of this communication and its attachments and =otify me immediately that you have received them in error. Thank you. From: Alan S=Halperin [mailto <mailto >1 Sent: Wednesday, February 26, 2014 11:39 AM To: Ada Clapp Cc: Christopher L Hurtado; Eileen Alexanderson; [email protected] <mailto:[email protected]> ; Richard J=slin Subject: Re: GRATs As to your=description of the required valuations, I agree. Please bear in mind=that this is a fluid process. Accordingly, if we wish to adopt another format -- such as a valuation of a 1% interest in BFP I am sure=that Empire would accommodate us. But I am okay with the format you =ave described. Alan IRS Circular 230 disclosure:=br> To ensure compliance with requirements imposed by the IRS, we inform you th=t any U.S. federal tax advice contained in this communication (including a=y attachments) is not intended or written to be used, and cannot be used, =or the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or =ecommending to another party any transaction or matter addressed herein. Click Here f=r More Information Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas New York, NY 10019-6064 <tel (Direct Phone) (Direct Fax <mailto From: &=uot;Ada Clapp" < To: A=an Cc: &=uot;Eileen Alexanderson" < <mailto "jeevacation@ mail.com&q=ot; <jeevacation=gmail.com <mailto:[email protected]», "Richard Joslin" <mailto:[email protected]» Date: 0=126/2014 10:18 AM Subject: GRATs <tel:Vc >, 2 EFTA_R1_01758448 EFTA02581760 Hi Alan and Chris, As you know, Leon is due to receive his first annuity payment =orm the APO1 GRAT No. 2 (dated December 4, 2013) on March 3, 2014. Please prepare the assignment form. We w=11 let you know the cash portion of the annuity after the dividend is paid= At Rich J.'s request, we would like the APO1 GRAT No. 3 =o be dated March 4, 2014 ( this will align the annuity payments for GRATs =o 2 and 3). Would you please prepare a new GRAT agreement and assignment form. I am assuming that Leon wishes to re-GRAT the B=P interests he received from the APO1 GRAT on January 24th and =he BFP interest he will receive from the GRAT No. 2 on March 3rdJeffrey-can you confirm that my understanding is correct? Regarding valuations, Leon will require a full valuation repor= for his gift to GRAT No. 3. Since Empire does not prepare its valua=ions showing the value of a 1% interest in BFP but rather the value of the entire interest transferred, if Leon re-GRATs BFP interes=s received on both January 24th and March 3rd,=GRAT No. 2 will need a separate restricted use valuation report (RUV=) for its in-kind distribution of the annuity payment to Leon on March 3rd. Likewise, the APO1 G=AT will need a RUVR for the January 24th in-kind distribution. =o you agree? Thanks in advance! Ada Clapp Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022 Direct Dial: Fax: Email: <mailto IRS Circular 230 Disclosure: Pursuant to IRS regulations, I inform you that any =ax advice contained in this communication (including attachments) is not i=tended or written to be used, and cannot be used, by any person or entity for the purposes of (i) avoiding tax related penaltie= imposed by any governmental tax authority, or (ii) proposing, marketing o= recommending to another party any transaction or matter discussed herein.= I advise you to consult with an independent tax advisor on your particular tax circumstances. This communication and any attachment is for the intended r=cipient(s) only and may contain information that is privileged, confidenti=l and/or proprietary. If you are not the intended recipient, you are hereby notified that =urther dissemination of this communication and its attachments is prohibit=d. Please delete all copies of this communication and its attachment= and notify me immediately that you have received them in error. Thank you. This message is intended only for the use of the Addressee and may con=ain information that is privileged and confidential. If you are not =he intended recipient, you are hereby notified that any dissemination of t=is communication is strictly prohibited. If you have received this c=mmunication in error, please erase all copies of the message and its attac=ments and notify us immediately. ********* *4.** ***** **•**= ******** * •*** ********* ****** *•** 3 EFTA_R1_01758449 EFTA02581761 The information contained in this c=mmunication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the a=dressee. It is the property of Jeffrey Epstein Unauthorized use, di=closure or copying of this communication or any part thereof is strictl= prohibited and may be unlawful. If you have received this communication in error, p=ease notify us immediately by return e-mail or by e-mail to [email protected], =nd destroy this communication and all copies thereof, including all attachm=nts. copyright -all rights reserved 4 EFTA_R1_01758450 EFTA02581762