EFTA Document EFTA01595280

Rosalia X Cracchiolo From: Sent: To: Subject: Karen G T-Io^rbacher Friday. March 2010 10 55 AM Resabia X Cracchiolo cinancial Trust Corr pany Firianial Trust Company says that it should 'use a W9 because it is an S corporation which has a single US owner, Normally you would not look through a corporation to its ..nderlying owners, but an S Corp has filed an election to do so with thy IRS. However, the regulations state that only a domestic coroorat..on can tile an S Corp election, and Financial Trust is not a domestic company it's a non -US company because it's in the N.irgiri Islands. Unfortunately I didn't have the regulation in front of me during the call or I would have asked. The client is going to send what he says is his S Corp election to you, so if you could send it I can take a look and see what he's actually talking about. There's a particular exception for US Virgin Islards corporations to be taxed as American that also involves a filing, and that might be what he means. Regards 'Karen Tmlhrr,a, Fier Tax Compiluncie Offker 1.p. Morgan Wealth Management Email. Direct Line: Group mailtx: 135 (il cute j30 Diiclosure JNJ,ilorgan Cnase & Co and its affiliates do not provide 7ax advice. Acccirding,y, any distussion of U.S.tax minters ontained term i;ificluding any attact-ments) is not intended or written to be Jsed, and cannot Le used, kr ;onnoction with the promotion, narketing or recornmendatiol try anyone unaffiliated with JP Morgan Chase & Co of any of the matters addressed herein or for the purse of avoiding U.S. tax -related penalties Rosalia X Cracchiolo From; Sent: To; Cc: Subject: Hi Karen G Rellow,ner Frioay March U, 201.0 4:21 PM Rosalie X Cracchioo Jeffrey H Malusow csg aigcicsei). held business RE. Financal Trust Ccmoany, Inc I believe this is sufficient. Please make sure that the Form 2553 election is scanned EFTA01595280 immediately behind the tax form when you receive it. Also we should find a valid form for Jeffrey E Epstein and make sure it is linked up to this account. For setup purposes, this is an international account (because its in the US Virgin Islands) but for tax purposes it is treated like a domestic entity. It should be set to issue a 1099 in the name of Jeffrey Epstein using his Social Security number. Although corporations do not normally get year-end reporting, this accourt shouA because it is an S corp -- meaning it elects to have the tax obligation passed to its shareholders (sort of to reverse of what an 6832 does for a partnership) Thanks Karen Karen Ronrbacner Tax Compliance Officer J.P. Morgan Wealtn Management Email: karen. .roh-bacnenOiDmcnag-com Direct Line: Group mailbox: P8 Tax Compliance :RS Circular 238 Disclosure JPMorgan Chase & Co. and its affiliates do not provide tax advice_ Accordingly, arty discussion of U.S. tax matters contained herein (including any attachments) is not intended or written to be used, and cannot be used, in connection with the promotion, marketing cr recommendation by anyone unaffiliated with JPMorgan Chase & Co. of any of the matters addressed herein or for the purpose of avoiding U.S. tax -related penalties. --Original Message -- Crow Rosalia X C-aLLhiolo Sent: Friday, March 05, 2010 1158 AM To: Karen G Rohrbacher Cc: Jeffrey M Matusow; csg aig closely held business Subject: FW: Financial Trust Company, Inc. hi, Attached is the S carp filing.. Please let me know what your thoughts are Regard Original Message From: Darren Indyke (rnailtolIIIIIIIIIIIIII) Sent: Friday, March e5, 2010 11:28 AM To: Rosana X Cracchiolo Subject: Financial Trust Company, Inc. Attached please find a better copy of the S Election and the only entry in the Stock Transfer Ledger of Financial Trust Company, Inc. Please note that Mr. Epstein is the only shareholder of Financial Trust Company, Inc, no EFTA01595281 shares have been issued other than the shares to Mr. Epstein, Thank You. Sincerely, Darren K. Indyke President Financial Trust CO y, Inc. ii,prl'. Fus TAX STATUS EXPLANATION Date[mmddyyyy Li3.022010 Box Mi -7 Deis Form Type "CITADEL" Dic Ode Dec 126L: LIOC 0! 1'1 inblYs Aar.: jr T•LfriD127i 01805001 Q30111005 W23E600.01 4,6166166166fe EFTA01595282