From: "Fenn, Patrick"

From: "Fenn, Patrick" To: jeffrey E. <[email protected]> CC: Melanie Spinella Subject: Re: privleged Date: Fri, 26 Aug 2016 12:51:17 +0000 Speaking with Suzanne Wong at 1130 to confirm no surprises. Patrick B. Fenn AKIN GUMP STRAUSS HAUER & FELD LLP Direct: On Aug 26, 2016, at 8:44 AM, jeffrey E. <jeevacation®gmail.com> wrote: first we must make sure that there is no tax difference.. so returns must be reviewed. On Fri, Aug 26, 2016 at 8:27 AM, Fenn, Patrick < wrote: No upside. Patrick B. Fenn AKIN GUMP STRAUSS HAUER & FELD LLP Direct On Aug 26, 2016, at 8:05 AM, jeffrey E. <[email protected]> wrote: i can be convinced. . though I prefer 3 years . only. . with a wait and see. On Fri, Aug 26, 2016 at 8:02 AM, Fenn, Patrick < wrote: Jeffrey, agree with this. But I don't see the benefit of not covering all the years back to 2007 given the stakes. That's only two more years of disclosure. Discuss at 11. Thanks Patrick B. Fenn AKIN GUMP STRAUSS HAUER & FELD LLP Direct: On Aug 26, 2016, at 7:11 AM, jeffrey E. <[email protected]> wrote: I can do call with both of you anytime before 11.. solution is easy, the only question is how far back . I have filed 8865 for leon since 13.. however they now appear to be inaccurate. but filed. statutes running.. mark and josh, have open statutes . -no filing however IRS has a policy not to go back beyond 6 yrs in general. . IRS program for just this purpose delinquent international disclosures. is EFTA00626743 easy. the only quesiion I have is do josh and mark file 3 years or 6 years. . of course filed along with the explanation from accounting for reasonableness. . if they file 3 yrs leon will not amend, if they file 6 leon will amend 10-12. I dont think the finger pointing for apollo deloitte , PWC is useful. please note 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 JEE 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], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. please note 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 JEE 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 jeevacation®gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. please note The information contained in this communication is confidential, may be attorney-client privileged, may EFTA00626744 constitute inside information, and is intended only for the use of the addressee. It is the property of JEE 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], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e- mail, and delete the original message. EFTA00626745