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From:
great
On Aug 12, 2013, at 12:31 PM, Darren Indyke wrote:
FYI
575 Lexington Avenue, 4th Floor
New York, New York 10022
Telephone: (212) 971-1314
Telecopier: (646) 350-0378
Mobile:
email:
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irk ******
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The information contained in this communication is confidential, may be attorney-client
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Darren K. Indyke, PLLC. Unauthorized use, disclosure or copying of this communication
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Copyright of Darren K. Indyke, PLLC - © 2011 Darren K.
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Begin forwarded message:
"Dlu ash, Alan"
Cc: "Darren K. Ind ke
Richard Kahn
>, "Guzman, Marylyn" <
Good Morning.
Friday at 11:00am EST is fine.
Please confirm.
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Thank you.
Gina
<image001.1pg>
GrNA M. BRYAN
OFFICE MANAGER
9100 PORT OF SALE MALL. STE 15
ST THOMAS, VI 00802-3602
Office: 340.779.2564
Fax:
888.316.9269
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 otherwise 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.
Cc: Darren K. Indyke (
); Richard Kahn; Guzman, Marylyn; Gina Bryan
I'll be unavailable for the next few hours so please coordinate with my assistant Gina
at
or by phone with what works for you. 340 779. 2564.
Sent from my iPhone
On Aug 12, 2013, at 11:32 AM, "Dlugash, Alan"
Erika,
> wrote:
Unfortunately I am not available from 10AM — 4PM tomorrow (Tuesday), and I leave Wednesday at 1:45 PM for
Panama where I'll be through Monday. l am OK with trying to call in from Panama Thursday or Friday at 11AM, but
the calls are not always reliable. What is your preference?
Alan
Please note my new mailing address:
Alan J. Dlugash
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Marks Paneth & Shron LLP
685 Third Avenue, New York, NY, 10017
P. 646 571 2424 F. 212-503-6359 C.
E.
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Cc: Darren K. Indyke (
); Richard Kahn
Alan,
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
<image002.jpg>
Notice: This communication may contain privileged or other conridential information. II 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 otherwise 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.
Cc: 'Darren Indyke' <
Dear Erika,
I am very much looking forward to our call Monday at noon. As I am still in the familiarization process with STC
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
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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.
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.
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.
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.
This transmission may contain confidential and/or privileged
information. This information is intended for use by the individual or
EFTA00385815
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.
EFTA00385816