EFTA02709637

From: Richard Joslin Sent: Saturday, March 22, 2014 3:14 AM To: Jeffrey Epstein Subject: Re: Attachments: Untitled attachment 00222.pdf; Tax Deferred Exchanges of Art and Other Collectibles.pdf Re Loan and Re Disqualified QI A loan to a QI or Exchange Accomodation Titleholder is permitted in a =everse exchange based on Rev Proc 2000.37. <=font> .03 =ermissible Agreements. Property will not fail to be treated as being =eld in a QEAA as a result of any one or more of the following legal or con=ractual arrangements, regardless of whether such arrangements contain term= that typically would result from arm's length bargaining between un=elated parties with respect to such arrangements:\ (1) An exchange accommodation titleholder that satisfies the requireme=ts of the qualified intermediary safe harbor set forth in §1.1031(k)&nda=h;1(g)(4) may enter into an exchange agreement with the taxpayer to serve =s the qualified intermediary in a simultaneous or deferred exchange of the=property under § 1031; (2) The taxpayer or a disqualified person guarantees some=or all of the obligations of the exchange accommodation titleholder, inclu=ing secured or unsecured debt incurred to acquire the property, or indemni=ies the exchange accommodation titleholder against costs and expenses; (3) The taxpayer or a disqualified person loans or advanc=s funds to the exchange accommodation titleholder or guarantees a loan or =dvance to the exchangeaccommodation titleholder; Re Disqualifed O1 I am looking to see if Gagosian transacted with Blacks within 2 year w=ndow. The Bryan Cave article references the Weirbicki article a=d expands analysis http://www.bryancave.com/files/Publication/8e2abb2a-1093-490f=a190- 0cec7496697e/Presentation/PublicationAttachment/961d6f73-1c5c-43cb-88=6- 1295b5942efd/Tax%20News%20and%20Developments%20(Fall%202013).pdf <http://www.bryancave.com/files/Publication/8e2abb2a-1093.49=f-af90- 0cec7496697e/Presentation/PublicationAttachment/961d6f73-1c5c-43cb-=8e6- 1295b5942efd/Tax%20News%20and%20Developments%20(Fall%202013).pdf> I attach articles by same author (one a panel discussion with Treasury=IRS) re 1031 and art. I am researching sales tax NY issue and reading exca=nge doc to see complience with Rev Proc and Ql/ EAT safe harbor. = On Fri, Mar 21, 2014 at 5:30 PM, Jeffrey Epstein=<[email protected] <mailto:[email protected]» wrote: http://www.aristitle.com/news/docs/Trusta=dEstatesArticle.pdf <http://www.aristitle.com/news/docs/TrustandEsta=esArticle.pdf> appears to eliminate gagosian as=a QI EFTA_R1_02117423 EFTA02709637 T=e information contained in this communication is confidential, may be a=torney-client privileged, may constitute inside information, and is int=nded only for the use of the addressee. It is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of thiscommunication or any part thereof is strictly prohibited and may be un=awful. 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 t=ereof, including all attachments. copyright -all rights reserved =/div> 2 EFTA_R1_02117424 EFTA02709638