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

From: "Jeffrey E." <[email protected]> To: Leon Black Subject: Date: Tue, 18 Apr 2017 17:07:54 +0000 The tax strategy is 100 percent legal, experts say, as long as all stages of the museum transfer are handled correctly. Schnitzer officials said that many California collectors had taken advantage of the tax provision. "We are on their way home," said Jill Hartz, the executive director of the museum. California explicitly outlines a "first use" exemption in its tax code. It says that property, whether a couch or a Caravaggio, that is first "used" out of state for more than 90 days does not incur the tax. Experts said that for many years it was known in art circles as the "Norton Simon rule," because Mr. Simon, an industrialist who died in 1993, was one of the first art collectors to make ample use of it with loans to several museums like the Portland Art Museum. 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 EFTA01049127