From: Darren Indyke <

From: Darren Indyke < To: Subject: Fwd: issues for conference call Date: Mon, 12 Aug 2013 12:27:29 +0000 Inline-Images: EOEB56D8-00A2-4239-A327-29A8633FC5E6[162].jpg Sent from my iPhone Begin forwarded message: From: Erika Kellerhals < Date: August 12, 2013, 6:40:22 AM I I) I To: "Dlugash, Alan" Cc: "Darren K. Indyke Subject: Re: issues for conference call Alan, , Richard Kahn < Thank you for your email. I am happy to address all of the issues you noted below — however — I now find myself in the situation where I learned last night that I have to fly to the states this morning. Is it possible for us to reschedule the call for either tomorrow at noon or Thursday between 9 and 12 or Friday between 9 and 1:30. I apologize for the last minute notice — but I only just learned that I would have to leave this am. Please advise. Erika A. Kellerhals Member VJ Notice: This communication may contain privileged or other confidential information. If you are not the intended recipient, or believe that you have received this communication in error. please do not print, copy, re-transmit, disseminate. or othenvise use this information. Also, please indicate to the sender that you have received this e-mail in error. and delete the copy you received. Thank you. Circular 230: To ensure compliance with the requirements imposed by the IRS, we inform you that any tax advice contained in our communication (including 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 another party any transaction or matter addressed herein. From: <Dlugash>, Alan Date: Monday, August 12, 2013 12:04 AM To: Erika Kellerhals Cc: 'Darren Indyke' < > Subject: issues for conference call Dear Erika, EFTA00385787 I am very much looking forward to our call Monday at noon. As I am still in the familiarization process with SIC and the related personal tax issues, I am hoping to learn much from the call and anticipate that we can complement each other with issues going forward. To assist with the call, I have listed below some issues that I hope we can cover in an overview level to help me along with USVI issues. I will also be glad to provide you with assistance in any area that you think I can help with. 1) Conditions related to USVI benefits, including concepts of 90% tax exemption, separate interest and dividend tax exemption, nature of business required to be conducted, sourcing of income issues, requirement of clients outside USVI, etc. 2) Complications related to the mirror concept of taxation, including possible issues relating to: a) LLC's b) trusts, including grantor trusts c) concept of nominee d) meaning of "foreign" e) Private Foundation and Not-for Profit entities 3) USVI taxing authority guidance, assistance, letter rulings, etc. 4) US state taxation issues 5) C corporation issues I would also like to know of any issues and concepts of which you think I should be aware. Alan Alan J. Dlugash Marks Paneth & Shron LLP 685 Third Avenue, New York, NY, 10017 P. 646-571-2424 F. 212-503-6359 C. 914.629.5658 E. Marks, Paneth & Shron IRS CIRCULAR 230 DISCLOSURE: Treasury Regulations require us to inform you that any Federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. CONFIDENTIALITY NOTE: This transmission may contain confidential and/or privileged information. This information is intended for use by the individual or entity named above. If you are not the intended recipient, be aware that any disclosures, copying, distribution or use of the contents of this information is prohibited. If you have received this transmission in error, please notify this office immediately. EFTA00385788