EFTA02679307

From: Ada Clapp Sent: Monday, April 8, 2013 10:19 PM To: Elyse G. Kirschner, CPA Thomas Turrin Cc: Eileen Alexanderson; Jeffrey Epstein Subject: Black Family 2012 Gift Tax Reporting Obligations Attachments: MWE Memo re 2012 Gift Tax Reporting.pdt Untitled attachment 00552.htm Hi =lyse and Tom, I wanted to follow up with you =egarding the need to report the gifts each of Debra, Ben, Josh, Alex =nd Victoria made to new trusts they each created in 2012, as outlined =n Elyse's attached memorandum. The memorandum implies =hat the family members will rely on the automatic allocation rules =nder the Treasury regulations for the allocation of GST exemption to =heir gifts. My preference is to make an affirmative allocation of =ST exemption on the gift tax return reporting the gift, where that is =he intention, rather than relying upon the automatic allocation rules. =nbsp;Not only is that the "safer" route, but it avoids confusion later =s to how much GST exemption was used by an individual, as you have =reated a record for all involved to refer back to. =nbsp; If you elect to rely on the automatic =llocation rules, would Elyse kindly confirm that the rules will =pply to allocate GST exemption to 100% of each family member's 2012 =ift (e.g., that they are indirect skips to "GST trusts" under the regs) = If instead, the gift tax returns will make affirmative =llocations of each family member's GST exemption, I would like the =pportunity to review the allocation =anguage. Thanks in advance for your =esponse. Best =egards, New York NY 10019 phone: IRS Circular 230 =isclosure: Pursuant to IRS regulations, I inform you that =ny tax advice contained in this communication (including attachments) =s not intended or written to be used, and cannot be used by any person =r entity for the purpose of (9 avoiding tax related penalties imposed =y any governmental tax authority, or (ii) promoting, marketing or =ecommending to another party any transaction or matter discussed =erein. I advise you to consult with an independent tax advisor on your =articular tax circumstances. This =ommunication, and any attachment, is for the intended recipient(s) only =nd may contain information that is privileged, confidential and/or =roprietary If you are not the intended recipient, you are hereby =otified that further dissemination of this communication and its =ttachments is prohibited. Please delete all copies of this =ommunication and its attachments and notify me immediately that =ou have received them in =rror. </=iv> EFTA_R1_01982352 EFTA02679307