EFTA02666795

From: Karp, Brad S Sent: Sunday, Decem er , : To: [email protected] Subject: Re: Fw: Draft Reasonable Cause Statement ACP/AWP I haven't heard a peep. Brad S. Karp I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019-6O64 (Direct Phone) (Direct Fax) From: jeffrey E. [mailto:[email protected] Sent: Sunday, December 11, 2016 04:34 PM To: Karp, Brad S Subject: Re: Fw: Draft Reasonable Cause Statement ACP/AWP Did you speak to him over the weekend? He's not returned text. ? Unusual I www.paulweiss.com On Fri, Dec 9, 2016 at 7:08 PM Karp, Brad S > wrote: Leon. 1 EFTA_R1_01918316 EFTA02666795 Brad S. Karp Partner Paul, Weiss, Rifkind, Wharton & Garrison LIP 1285 Avenue of the Americas New York, NY 10019-6064 (Direct Phone) I(Direct Fax) www.paulweiss.com <http://www.paulweiss.com> From: Okun, Brad R Sent: Friday, December 09, 2016 03:20 PM To: [email protected] <mailto Cc: Karp, Brad S; Brad Wechsler Subject: Draft Reasonable Cause Statement ACP/AWP 2 EFTA_R1_01918317 EFTA02666796 Leon, as discussed: Attached are two draft reasonable cause statements related to the Forms 8865, 8858 and 5471 that we have been discussing. The first statement is intended to be used for the 2007-2012 tax years and would be replicated for each year so a separate statement is filed with each Form 1040X that is filed. The second statement is intended to be used for the 2013-2014 tax years. This statement is based on the first but contains some differences in the background paragraph, which reflect the fact that (i) the K-1 provided for those years explicitly stated that no foreign filings were required and (ii) notwithstanding the footnote, a Form 8865 was in fact filed for BRH for 2013 and 2014. The attached pdf redline highlights the changes between the two statements. Let me know if you would like to discuss. This message is intended only for the use of the Addressee and may contain information that is privileged and confidential. If you are not the intended recipient, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this communication in error, please erase all copies of the message and its attachments and notify us immediately. 3 EFTA_R1_01918318 EFTA02666797