From: Eileen Alexanderson <

From: Eileen Alexanderson < To: 'Jeffrey Epstein' Subject: FW: Debra Black Date: Mon, 03 Dec 2012 19:50:48 +0000 > > From: Kirschner, Elyse [mailto: Sent: Monday, December 03, 2012 12:30 PM To: Eileen Alexanderson Cc: Thomas Turrin; McCaffrey, Carlyn Subject: Debra Black Eileen, I Tom Turrin sent me Debra's last gift tax return (2007). It looks like Debra has already used $1 million of her gift tax credit on gifts from 1988 through 2005. As of 2007, she had used only $53,596 of her GST exemption. Has Debra made any taxable gifts or allocated any portion of her GST exemption earlier this year? Assuming that the answer to this question is no, Debra can gift to her new trust up to approximately $4.12 million before the end of the year without paying any gift tax. However, she has $5,066,404 of her GST exemption remaining. She may want to transfer to the new trust $5,066,404 and allocate her entire remaining GST exemption to the new trust, even if it means paying gift tax (at a 35% rate) on an amount equal to the difference between $5,066,404 and $4,120,000. It may be worth it for her to pay some gift tax to enable her to get an additional $950,000 of GST exempt property into the trust. Please let me know if you have any questions. Elyse Elyse G. Kirschner I Partner McDermott Will & Emery LLP * • ip********.k• *********Io• • %WY • II* **tap • *tab • %WY • **********• • it** • II* *IN tap • **Io • • MI* • II* *******************• • it* ********* *** • IRS Circular 230 Disclosure: To comply with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained herein (including any attachments), unless specifically stated otherwise, is not intended or written to be used, and cannot be used, for the purposes of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter herein. This message is a PRIVILEGED AND CONFIDENTIAL communication. This message and all attachments are a private communication sent by a law firm and may be confidential or protected by privilege. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of the information contained in or attached to this message is strictly prohibited. Please notify the sender of the delivery error by replying to this message, and then delete it from your system. Thank you. ***• • *Hai II* FY tap • **IN • • MI* • II* FY tap • **IN • • *to • II* *************•• • *** • • it* ********** Ith • Please visit for more information about our Firm. EFTA00683589 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 EFTA00683590