From: Thomas Turrin

From: Thomas Turrin To: Jeffrey Epstein <[email protected]> Subject: RE: Re: Date: Tue, 21 May 2013 12:38:53 +0000 Inline-Images: rem-newlogo_sm29.png; primeglobal_color blktext_tagline4823jpg; 2012_ipa100(2)18bejpg Even if gift made from joint account, if both spouses do not consent to the gift —then gift is made by one spouse...reported by one spouse. From: Jeffrey Epstein [mailto:[email protected]] Sent: Tuesday, May 21, 2013 8:34 AM To: Thomas Turrin Subject: Re: Yes to idea, does 2513 apply to joint accts On Tuesday, May 21, 2013, Thomas Turrin wrote: Jeffrey, The reporting of gifts made by Leon on his return only is correct... Under Section 25I3(a) of the Code, a gift by a husband to a third party is considered to be made one-half by him and one-half by his wife as long as she is a citizen or resident of the US. However, this rule applies only if both spouses have signified their consent to its application. When the wife does not consent the gift is from the husband only. I would, however, recommend that a different account be set up (not joint) — or perhaps a type of discretionary trust could be set up from which gifts can be made to whomever the grantor wishes — with no disclosure of donees on gift tax return necessary... the gift to the trust would be the reportable gift — I would discuss with estate and trust counsel. Trustee would make gifts in its discretion from trust account. Best, Tom THOMAS TURRIN, CPA Partner Raich Ende Malter & Co. LLP EFTA01135700 Email: Website: From: Jeffrey Epstein [mailto:jeevacationagmail.com Sent: Monday, May 20, 2013 5:03 PM To: Thomas Turrin Subject: Re: if the money comes from a joint acct, isnt it considered a 50/50 gift? On Mon, May 20, 2013 at 4:35 PM, Thomas Turrin < > wrote: It is my understanding that Leon signs all checks and makes all decisions regarding the account in question. THOMAS TURRIN, CPA Partner Raich Ende Malter & Co. LLP Email: Website: EFTA01135701 From: Jeffrey Epstein [mailto:[email protected] Sent: Monday, May 20, 2013 2:40 PM To: Thomas Turrin Subject: it appears many if not all of leons gifts were made from a joint bank acct. ? were you aware of this, ? isn't half the gift attributable to Debra? ********************* **** 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 RAIC ENDE MALT O. LAP w INSTIDEBnot P 51100 •FIRMS PrimeGlobal An Association of Independent Accounting Firms CONFIDENTIALITY STATEMENT: The information contained in this electronic communication, including any and all attachments and enclosures, may be privileged and is strictly confidential, intended solely for the use of the person(s) identified above to receive this communication. If you are not the person(s) identified above to receive this communication, you are hereby notified that you may not disclose print, copy, disseminate. or otherwise use the information contained herein. If you are an employee or agent of the person(s) identified above to receive this communication and. as such, you have been authorized to deliver this communication to such person(s), you may disclose, print copy. disseminate. or otherwise use the information contained in this communication solely for the purpose of such delivery. Unauthorized interception and/or use of this communication arefis strictly prohibited and may be punishable by law. If you have received this communication in error. please reply and notify the sender (only) of that fact and delete the communication. including any and all attachments and enclosures. from your computer or other electronic device on which you may have received this communication. CIRCULAR 230 DISCLOSURE: To insure compliance with requirements imposed by the Internal Revenue Service. we inform you that any tax advice contained in this communication (including any and all attachments), unless expressly stated otherwise, was not intended or written to be used and cannot be used for the purpose of (i) avoiding tax-related penalties imposed by the Internal Revenue Code or (ii) promoting, marketing. or recommending to another party any EFTA01135702 transaction(s) or tax-related matter(s) addressed herein. This communication may not be forwarded (other than to the addressee(s) identified above) without our express written consent. EFTA01135703