From: Eileen Alexanderson ctl

From: Eileen Alexanderson ctl To: "Jeffrey Epstein ( Subject: FYI: foundation Date: Thu, 06 Dec 2012 16:53:13 +0000 Attachments: Form_of Foundation_Letter_NAME_REDACTED.pdf ).. From: Clapp, Ada [mailto: Sent: Wednesday, December 05, 2012 5:26 PM To: Eileen Alexanderson Subject: RE: foundation Hi Eileen, I prepared the attached letter for a client in July (redacted the names to protect the innocent). You may find it helpful. It discusses the pros/cons of one form versus the other. Thanks for keeping me posted. Ada Clapp Managing Director, Wealth Strategist U.S. Trust Bank of America Private Wealth Management 114 West 47th Street New York. New York 10036 IRS Circular 230 Disclosure: Pursuant to IRS regulations, we inform you that any tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used by any person or entity for the purpose of (i) avoiding tax related penalties imposed by any governmental tax authority or agency, or (ii) promoting, marketing or recommending to another party any transaction or matter discussed herein. We advise you to consult with an independent tax advisor on your particular tax circumstances. From: Eileen Alexanderson [mailto: Sent: Wednesday, December 05, 2012 5:14 PM To: Clapp, Ada Subject: foundation I spoke to Ralph Lerner re setting up new Art Foundation yesterday. He recommends a Delaware corporate 'lending foundation' which has a mission statement of lending art to museums. It would definitely be an operating foundation. Leon would therefore get credit for donation of the FMV of the art contributed. Leon could donate several artworks that are presently out on loan and get credit for the charitable donation. At seminar this moming, reps from the Foundation Source also recommended a Delaware Corp. Both said to stay away from a NY Corporation. As you know Jeffrey favored that format also. The intention would not be to set up for a museum just yet, I would think we would potentially transition this foundation or set up a new one if Leon wants to go that route down the road. Comments on trust format instead of a corporate one ranged from That's what the T&E lawyers do" to That's the old fashioned approach". I have not been able to determine though, whether Delaware has the same type of "burden" cited when using a NY corp related to the State Board of Regents. EFTA00671623 Eileen Alexanderson Black Family Partners, do Apollo Management 9 W 57th Street New York NY 10019 email: This email and any files transmitted with it are confidential and intended solely for the person or entity to whom they are addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other than the intended recipient is prohibited. If you have received this email in error please contact the sender and delete the material from any computer. Apollo Global Management, LLC This message, and any attachments, is for the intended recipient(s) only, may contain information that is rivileged, confidential and/or proprietary and subject to important terms and conditions available at If you are not the intended recipient, please delete this message. This email and any files transmitted with it are confidential and intended solely for the person or entity to whom they are addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other than the intended recipient is prohibited. If you have received this email in error please contact the sender and delete the material from any computer. Apollo Global Management, LLC EFTA00671624