From: "Dlugash, Alan"

From: "Dlugash, Alan" To: Jeffrey Epstein <[email protected]> CC: Richard Kahn Subject: FW: grantor trust reporting Date: Mon, 14 Sep 2015 03:13:12 +0000 Attachments: APO2 DECLARATION_-_ATTACHMENT_TO_1041_(2014)_REVISED_COURIER.pdf Alan J. Dlugash Marks Paneth & Shron LLP 685 Third Avenue, New York, NY, 10017 P. 212-753-8777 F. 212-503-6359 C. 914.629.5658 E. ,Marks, Paneth & Shron From: Richard Joslin [ Sent: Sunday, September 13, 2015 4:36 PM To: Dlugash, Alan Subject: grantor trust reporting Alan: We have discussed in past that disregarded entities, ie single member LLC's should not have tax ID's and not file tax returns. Similarly, grantor trusts that own disregarded entities should not report the underlying income of the disregarded entities. The grantor would report all underlying income on the grantor individual tax return. As the grantor trusts have tax ID's, we got sign off from Paul Weiss on the above (see email below), ie grantor trust disclose that underlying entity K-1 income is not reported on grantor trust return and will be reported on grantor's tax return. Attached is a 1041 rider that I'd like to to see (one page) that states that grantor will report K1 items for a list of entities. From: Halperin, Alan S Sent: Friday, August 7, 2015 7:32 AM To: Richard Joslin Cc: John Castrucci; Bronstein, Richard J; Brad Wechsler Subject: RE: floating an idea re grantor trust reporting Rich, it was good seeing you yesterday and discussing this issue. I wish to confirm that we agree with your analysis of the rules concerning the reporting of grantor trusts and disregarded entities. We further agree with your proposal for 2014. As we discussed, we recommend that, for 2015 and future years, so long as the entities continue as grantor trusts and disregarded entities, you proceed with the approach described for 2014 (rather than the procedure described in the memo for 2015). While your suggested approach for 2015 is permitted, it may create additional work once the trusts cease to be grantor trusts and/or upon a disregarded entity becoming a partnership for tax purposes. I am happy to discuss. Alan EFTA00846226 Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019-6064 (212) 373-3313 (Direct Phone) I (212) 492-0313 (Direct Fax) From: Richard Joslin [mailto: Sent: Wednesday, August 05, 2015 10:06 AM To: Halperin, Alan S Cc: John Castrucci; Bronstein, Richard Subject: floating an idea re grantor trust reporting Alan: I hope this finds you well. I prepared a one page analysis and proposal to deal with income tax reporting for disregarded entities, LLC's owned by grantor trusts, and single grantor owner grantor trusts. We have discussed this in the past and I hope you can take a look at the attached in advance of the Thursday meeting. Thanks RJ This message is intended only for the use of the Addressee and may contain information that is privileged and confidential. If you are not the intended recipient, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this communication in error, please erase all copies of the message and its attachments and notify us immediately. Any tax advice in this e-mail should be considered in the context of the tax services we are providing to you. Preliminary tax advice should not be relied upon and may be insufficient for penalty protection. CONFIDENTIALITY NOTE: 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. EFTA00846227