From: "Jeffrey E." <[email protected]>

From: "Jeffrey E." <[email protected]> To: Richard Joslin Subject: Re: we're calling the sales tax guy at 6:30 pm - I'll come to your office Date: Wed, 03 Jun 2015 12:18:36 +0000 very strong opinion from you that belies the fact that you dont have real facts. stilly and should be stopped immediatley On Wed, Jun 3, 2015 at 7:23 AM, Richard Joslin < > wrote: Each charter agreement states the location of the charter and 100% of all charter activity has taken place outside the US per the captain. The location of the chartering /transportation service is dispositive to the tax questions of sales tax and sourcing of income. The captains log will provide location of boat by day and there is other documentary evidence ofboat's position can be provided in audit. The boat's location during the charter period rather than the fact that BJAV may have US presence via agents or employees is the controlling factor. From: Jeffrey E. [mailto:[email protected] Sent: Wednesday, June 03, 2015 6:05 AM To: Richard Joslin; Brad Wechsler; Heather Gray Subject: Re: we're calling the sales tax guy at 6:30 pm - I'll come to your office sorry but this is emblematic of the silliness that appears to continue. 1. How can we ask for a legal opinion when it is crystal clear that we don't yet have accurate facts or numbers , f. 2 Invoices have not been reviewed! corporate structure is convoluted and unexplored in detail. ( was the boat captain on the call?) 3 Paul weiss is the attny , and should be charged with getting us info. . 4. Bringing in yet another outside lawyer without full vetting and consideration, a waste of time energy and money. . 5. ex. what is the location of charters shown on the invoice? do you know. . ? if th invoices are incorrect, does that give us any comfort in trying to defend an audit. . I saw three invoices only, and each had a different owner or address . . On Tue, Jun 2, 2015 at 9:15 PM, Richard Joslin < > wrote: Begin forwarded message: From: Brad Wechsler Date: June 2, 2015 at 7:49:41 PM EDT To: Heather Gray Cc: Richard Joslin Subject: Re: we're calling the sales tax guy at 6:30 pm - I'll come to your office Reply-To: Brad Wechsler C Excellent; rich you will let jeffrey know, I assume. See u tomorrow. EFTA00855351 Sent from my Verizon Wireless BlackBerry From: Heather Gray <I Date: Tue, 2 Jun 2015 23:17:26 +0000 To: Brad Wechsler Cc: Richard Joslinti Subject: FW: we're calling the sales tax guy at 6:30 pm - I'll come to your office Just an FYI, Brad, the lawyer we spoke with is Richard Leavy at Sidley — he's he guy that Rick Bronstein recommended to us. I had spoken with him last week about sales tax on art and he seems very qualified. I spoke with him earlier today to have him send us an engagement letter and he mentioned that he also had experience with yachts and planes, so he seemed like the right person to speak with on the BJAV question. From: Richard Joslin Sent: Tuesday, June 02, 2015 7:07 PM To: Brad Wechsler Cc: Heather Gray Subject: RE: we're calling the sales tax guy at 6:30 pm - I'll come to your office We consulted state and local tax attorney re sales tax and NYS/C income tax re BJAV. Conclusion: zero risk of NYS sales tax on charter or transportation services conducted outside the US despite the NYC presence, eg bill pay personnel, NY address on invoices, director (EA). Conclusion: income from charter/ transportation services would not be sourced to US, nor sourced to NYS or NYC despite the NYC presence, eg bill pay personnel, NY address on invoices, director (EA) . From: Heather Gray Sent: Tuesday, June 02, 2015 6:14 PM To: Richard Joslin Subject: we're calling the sales tax guy at 6:30 pm - I'll come to your office Heather Gray Elysium Management LLC EFTA00855352 445 Park Avenue Suite 1401 New York, New York 10022 Direct Dial: it589-o3L5 Fax: &t5£1,9th: 30 Email: 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 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 EFTA00855353