From: Heather Gray

From: Heather Gray To: "Jeffrey Epstein ([email protected])" <[email protected]> Subject: FW: sales tax Date: Thu, 30 Apr 2015 22:33:10 +0000 Hi Jeffrey, Paul Weiss agrees that the trade-in credit applies to art. This is the tax partner that Alan had weigh in: http://www.paulweiss.com/professionals partners-and-counselirichard-j-bronstein.aspx. Best, Heather From: Halperin, Alan S [mailto Sent: Thursday, April 30, 2015 6:29 PM To: Heather Gray Cc: Ada Clapp; Bronstein, Richard.' Subject: RE: sales tax We agree. Thanks. Alan Alan S. Halperin I Partner Paul, Weiss, Rif kind, Wharton & Garrison LLP I New York, NY 10019-6064 (Direct Phone) (Direct Fax) From: Heather Gray [mailto: Sent: Thursday, April 30, 2015 5:54 PM To: Halperin, Alan Cc: Ada Clapp Subject: sales tax Hi Alan, So nice speaking with you earlier today, and I hope you feel better soon) As I mentioned on our call, I wanted to check in with your sales tax people as to whether they think the trade-in credit provided under NY Sales and Use Tax Regulations section 526.5(f) applies to a trade-in of art to an art dealer. (For the record, I believe that it does.) The scenario we are imagining is as follows: Collector wants to buy Artwork A from Gallery for $100. Gallery is a NYC art gallery that is in the business of buying and selling works of art. Collector and Gallery agree that Collector will trade in Artwork B in part payment for Artwork A. Gallery gives Collector credit for $75 (the value of Artwork B) and charges Collector $25 cash plus NY sales tax on $25. Gallery intends to sell Artwork B to a different client. Thanks, Heather Heather Gray EFTA00857993 Elysium Management LLC New York, New York moat Direct Dial: Fax: Erna' : 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. EFTA00857994