EFTA02706801

From: Erika Kellerhals Sent: Friday, January 4, 2013 7:26 PM To: Jeffrey Epstein Subject: Re: Attachments: 788896A5-A17A-4855-9256-438DEEA09109[129].png; 788896A5- A17A-4855-9256-43BDEEA09109[123].png III send response — but right now working on tax court petition due =oday. Erika A. Kellerhals Partner Kellerhals Ferguson Fletcher Kroblin LLP Suite 15 St. Thomas, U.S. Virgin Islands 00802 Office Fax: Notice: This communication may contain privileged or other confidenti=l information. If you are not the intended recipient, or believe tha= you have received this communication in error, please do not print, copy,=re-transmit, disseminate, or otherwise use this information. Also, please indicate to the sender that you have =eceived this e-mail in error, and delete the copy you received. Than= you. EFTA_R1_02102944 EFTA02706801 Circular 230: To ensure compliance with the requirements imposed by the IRS= we inform you that any tax advice contained in our communication (includi=g any attachments) was not intended or written to be used, and cannot be u=ed, for the purpose of (i) avoiding any tax penalty or (ii) promoting, marketing or recommending to another pa=ty any transaction or matter addressed herein. From: Jeffrey Epstein <[email protected]> Date: Friday, January 4, 2013 9:38 =M To: Erika Kellerha Notice: This communication may contain privileged or other conf=dential information. If you are not the intended recipient, or belie=e that you have received this communication in error, please do not print, copy, re-transmit, disseminate, or otherwis= use this information. Also, please indicate to the sender that you =ave received this e-mail in error, and delete the copy you received. =Thank you. Circular 230: To ensure compliance with the requirements imposed by t=e IRS, we inform you that any tax advice contained in our communication (i=cluding any attachments) was not intended or written to be used, and cannot be used, for the purpose of (i)=avoiding any tax penalty or (ii) promoting, marketing or recommending to a=other party any transaction or matter addressed herein. 2 EFTA_R1_02102945 EFTA02706802 From: Jeffrey Epstein <[email protected]</=» Date: Friday, Janua 4 2013 8:49 =M To: Erika Kellerhals Subject: Re: so if us residents own common shares in our new bank,? why=is my holding of a 100 percent intrest as a us person not included, On Fri, Jan 4, 2013 at 8:32 AM, Erika Kellerhals= <[email protected] <mailto:[email protected]> wrote: An entity =ncorporated in the USVI is considered a foreign corporation for the purpos=s of the unmirrored Internal Revenue Code. Therefore, when U.S. shareholders control a USVI =orporation under the S0% rule ( U.S. shareholders own more than 50% of the=combined voting power of its stock or more than 50% of the total value of the stock) the USVI corporation is treated as a CFC (a="USVI CFC"). To the extent that a USVI CFC invests its earnings in United States =roperty or earns subpart F income in the form of foreign base company sale= income, foreign base company services income, or foreign personal holding=company income, its United States shareholders are taxed on such investment in United States property and su=part F income to the same extent as if such corporation were formed in a f=reign country Erika A. Kel=erhals 3 EFTA_R1_02102946 EFTA02706803 Notice: This communication may contain privileged or other conf=dential information. If you are not the intended recipient, or belie=e that you have received this communication in error, please do not print, copy, re-transmit, disseminate, or otherwis= use this information. Also, please indicate to the sender that you =ave received this e-mail in error, and delete the copy you received. =Thank you. Circular 230: To ensure compliance with the requirements imposed by t=e IRS, we inform you that any tax advice contained in our communication (i=cluding any attachments) was not intended or written to be used, and cannot be used, for the purpose of (i)=avoiding any tax penalty or (ii) promoting, marketing or recommending to a=other party any transaction or matter addressed herein. From: Jeffrey Epstein <[email protected]</=» Date: Thursday, January 3, 2013 7:0= PM To: Erika Kellerhals Subject: <no subjec how do the cfc rules apply to us residents holding shares in vi corp.<=r clear="all"> The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of 4 EFTA_R1_02102947 EFTA02706804 Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 5 EFTA_R1_02102948 EFTA02706805