EFTA02720942

'eevacation mail.com 'eevacation mail.comj: Christopher L Hurtado c: tneen aaexanaerson jeevacationftmaitcom[jeevacationelgmailcom]: Richard Joslini From: Ada Clapp Sent Wed 2/26/2014 3:17:36 PM Subject: GRATs Hi Alan and Chris, As you know, Leon is due to receive his first annuity payment form the APOI GRAT No. 2 (dated December 4, 2013) on March 3, 2014. Please prepare the assignment form. We will let you know the cash portion of the annuity after the dividend is paid. At Rich J.'s request, we would like the APOI GRAT No. 3 to be dated March 4, 2014 ( this will align the annuity payments for GRATs No 2 and 3). Would you please prepare a new GRAT agreement and assignment form. I am assuming that Leon wishes to re-GRAT the BFP interests he received from the APO I GRAT on January 24°' and the BFP interest he will receive from the GRAT No. 2 on March 3nd. Jeffrey-can you confirm that my understanding is correct? Regarding valuations, Leon will require a full valuation report for his gift to GRAT No. 3. Since Empire does not prepare its valuations showing the value of a 1% interest in BFP but rather the value of the entire interest transferred, if Leon re-GRATs BFP interests received on both January 24th and March 3s, GRAT No. 2 will need a separate restricted use valuation report (RUVR) for its in-kind distribution of the annuity payment to Leon on March 3rd. Likewise, the APO I GRAT will need a RUVR for the January 24°' in-kind distribution. Do you agree? Thanks in advance! Ada Clapp Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022 E FTA_R1_02204656 EFTA02720942 Direct Dial: Fax: ■ Email: • IRS Circular 230 Disclosure: Pursuant to IRS regulations, I inform you that any tax advice contained in this communication (including attachments) is not intended or written to be used, and cannot be used, by any person or entity for the purposes of (i) avoiding tax related penalties imposed by any governmental tax authority, or (ii) proposing, marketing or 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 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 further dissemination of this communication and its attachments is prohibited. Please delete all copies of this communication and its attachments and notify me immediately that you have received them in error. Thank you. E FTA_R1_02204657 EFTA02720943