From: "Ada Clapp" a

From: "Ada Clapp" a To: <jeevaeation4gmail.com> Cc: "'Richard .loslin"' < , "'Eileen Alexanderson"' Subject: Planning Meeting Date: Wed, 08 Jan 2014 22:13:40 +0000 Hi Jeffrey, Rich mentioned that you might want to have a meeting next week to discuss various issues (including estate tax issues) relating to art owned by the various trusts and entities. Unfortunately, I am in Orlando at an estate planning conference all next week. Eileen and I are both free on Friday of this week. Would anytime on Friday work for you? Also, I would like to add to the agenda a quick discussion of the APO2 Trust and the sub-trust you and I briefly discussed. To refresh your recollection, the sub-trust would need to be added to the APO2 Trust (not yet signed) to enable it to hold the joint life policies currently held in the split-dollar insurance trusts, once we roll out the split dollar agreements. Including the sub-trust gives us the flexibility to retain the insurance (and perhaps convert it to a more favorable policy), which Leon indicated to Eileen that he may wish to do. We need to make a decision on the sub-trust before we can move forward with the decanting of the 1997 Trust. Also, we need to factor this into the plan to upwind the split dollar arrangements when we speak with Norman Brownstein regarding phase 2 of the roll-out (i.e., what to do with the policies once the trusts own them). Please let me know if Friday works for you. Best regards, Ada Clapp Black Family Partners 445 Park Avenue New York, New York 10022 Dire 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. EFTA00653004