From: Jeffrey Epstein <jeevacationggmail.com>

From: Jeffrey Epstein <jeevacationggmail.com> To: Melanie Spinella Subject: Fwd: Date: Mon, 13 Jan 2014 12:12:04 +0000 Forwarded message From: Alan S Halperin Date: Mon, Jan 13, 2014 at 7:57 AM Subject: Re: To: Jeffrey Epstein <jeevacation(ipgmail.com> In providing you with my previous answer, I had assumed that the decedent owned an interest in the entity. My previous email therefore described how his ownership interest in the entity would be reflected. The trusts ownership interest, in turn, would not be shown directly on any schedule on the 706. Rather, in response to questions in the 706, you attach riders describing various trusts associated with the decedent. Generally, we do not disclose on the 706 the assets of trusts not subject to estate tax. However, during the audit, the IRS often asks about the trust assets. If the decedent owns the art directly, it is reflected on Schedule, with a supporting appraisal. The artwork then will be sent to the Art Panel for valuation by the IRS. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. Click Here for More Information Alan S. Halperin I Partner Paul. Weiss. Rifkind. Wharton 8 Garrison LLP (Dir ac Americas I 19-6064 Dir t Phone) Direct Fax) I AN vw.paulweiss.com From: 'Jeffrey Epstein" < °vacation mail.com> To: Man S Halperin Dale: 01/13/2014 06:49 AM Subject: Re: and if owned personally EFTA00871449 On Mon, Jan 13, 2014 at 7:45 AM, Alan S Halperin > wrote: There would be one entry, in Schedule B (if a corporation) or F (if a partnership or LLC), with the name of the entity and the value. In addition, there would be an appraisal which would describe the entity (structure, history, ownership,purpose and assets) and the valuation. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. Click Here for More Information Alan S. Halperin I Partner Paul, Weiss, Rifkind. Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019-6064 (Direct Phone) I (a. (Direct Fax) I wv.w.paulweiss.com From: 'Jeffrey Epstein" <eevacation mail.com> To: Alan S Helped Date: 01/13/2014 06:34 AM Subject: Re: what would the 706 look like , if it were in a partnership or even a c corp. On Mon, Jan 13, 2014 at 7:29 AM, Alan S Halperin > wrote: It helps, in my view, if rent is being paid. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York NY 10019-6064 (Direct Phone) Direct Fax) From: "Jeffrey Epstein" [[email protected]] Sent: 01/13/2014 07:23 AM AST EFTA00871450 To: Alan Halperin Subject: Re: doesn;t a formal structure partnership . give us another layer of practical protection, valuing the art as a partnership asset.. etc. On Mon, Jan 13, 2014 at 5:30 AM, Alan S Halperin < wrote: Well, if the goal is avoiding 2036, the best choices are (a) trust-owned art where Debra is a beneficiary (without necessarily having any rent, but with a use agreement), or (b) trust-owned art with Leon paying rent. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP the Americas I New York. NY 10019-6064 (Direct Phone) I (Direct Fax) www.paulweiss.com From: jeevacation Sent: 01/12/2014 10:07 PM EST To: Alan Halperin Subject: Re: Don't get lost. I care little about income imputation. The question is 2036!, and strengthening your comfort level Sony for all the typos .Sent from my iPhone On Jan 12, 2014, at 9:53 PM, "Alan S Halperin" wrote: As I reflect further, while the corporation cases are distinguishable from the partnership scenario, because the tax regimes are different, I am concerned that rent-free use of partnership property could give rise to compensation income (as opposed to dividend income). The idea of converting the partnership into an active art business entity in fact lends itself to this result. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019-6064 EFTA00871451 Direct Phone) I www.paulweiss.com Direct Fax) From: "Jeffrey Epstein" Ueevacation®gmail.com Sent: 01/12/2014 05:23 PM AST To: Alan Halperin I we formed an invesmtent partnership . to invest in art. and the trust and leon were partners. add his collectibles. . and he arguably used partnership assets what is the risk. deemed distribution on non existnat rent? seperate from 2036, maybe some alternative assets also added. ? 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 Jeffrey Epstein 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 jeevacation®gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved if 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. 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. 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 Jeffrey Epstein 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 jeevacation®gmail.com, and EFTA00871452 destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 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. 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 Jeffrey Epstein 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 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. 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 Jeffrey Epstein 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 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. EFTA00871453 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 Jeffrey Epstein 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 EFTA00871454