EFTA Document EFTA01897634

To: Melanie SpineHal From: Jeffrey Epstein Sent Tue 4/2/2013 11:21:28 AM Subject: Fwd: Forwarded messa e From: Alan S Halperin Date: Tue, Apr 2, 2013 at 7:16 AM Subject: Re: To: Jeffrey Epstein [email protected]> I thought you would appreciate the reference. 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, Wain, Rilkind, Wharton 8 Garrison LLP 1285 Avenue of tho Amoncas I New York. NY 10019-8084 (212)373-3313 (Direct Phone) I i2121492-0313 (Direct Fax) [email protected] I *vow beluiw44$4sOM From: 'Jeffrey Epstein' < eeva-attor 4?. mail corn> To: Alan S Halperin/PaulWoissraulWeiss Date: 04/02/2013 07:07 AM Subject: Rs: of course agreed, there arc many potential , but I would like our begiinng to be he has the stock- the children a note.- and craft it from there, a new grat. ? your partnership. are merely two of our choices. I think there needs to be a priority on the now. rather than only the hereafter . RE: your carlyn comment. can we use it against your yesterdays well deserved credit? EFTA_R1_00323917 EFTA01897634 On Tue, Apr 2, 2013 at 7:00 AM, Alan S Halperin <A II alperinApituk eiss.com> wrote: Fair enough. But Carlyn also thought that she was getting Leon what he wanted. We need to balance the dual objectives of satisfying his objectives, while building a plan that is viable from a tax perspective. I think a swap for a note is fine on short term basis. But it is not a sustainable, long-term solution. We need to have an viable exit strategy. Agreed? 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 Pennon Paul, Weiss, Ftilltind, Wharton 8 Garrison LLP 1285 Avenue of the Americas I Now Yoe*. NY 100194064 f212) 373-3313 (Direct Phone) l %212) 492-0313 (Direct Fax) ahalimilnaPoulwpos corn I minx POuNfons corn From' 'Jeffrey Epstein' cloov.,cptionagmail com> To: Alan S Halperin/PaulWeiss4PaulWeiss Date. 04/02/2013 06:55 AM Subject- Re: getting Icon what he wants On Tuc, Apr 2, 2013 at 6:52 AM, Alan S Halperin <A Ylalperinitg pauk eks coin> wrote: When you say remove the stock, are you referring to the trust's interest in Black Family Partners? 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 EFTA_R1_00323918 EFTA01897635 Alan S. Halperin I Partner Paul, Weiss, Rilkind, Wharton 8 Garrison LLP 1285 Avenue of Americas I New York. NY 10019-6064 i2121 373-3313 (Direct Phone) I (212)492-0313 (Direct Fax) [email protected] I uninv.pautyLejss cum From: 'Jeffrey Epstein' climgreitioresimeijsonp To: Alan S Halparin/PaulWeiss@PautWeiss Date: 04/02/2013 06:48 AM Subject: Re: I think we shouls use the power of substituuion and remove the stock. from the 2006 trust , form the new entity contribute the new corpus, it could be shares of an entity that had a collateral note ( collaterialize.d by both the stock and art for example. or bank note or letter of credit backed I think however that you should explain your estate frieze to leon and debra on wed. . just its essence as if we were to go that route we would have to detail it. On Tue, Apr 2, 2013 at 6:38 AM, Alan S Halperin <[email protected]> wrote: I agree. 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, Rilkind. Wharton 8 Garrison LLP 1285 Avenue of the Americas I Now York, NY 10019-6064 "41;3,3311 (Direct Phone) I j2121492-0313 (Direct Fax) ;lho'Pci•^ZPourveoi com. I ‘._vviieuiathattlitsan From: "Jeffrey Epstein" ereeyacatior /•: .;rr To: Man S Halperin/PaulWeiss@PaulWeiss Date: 04/022013 06:35 AM Subject: Re: EFTA_R1_00323919 EFTA01897636 this would be a decanting before the ultimate distribution. I woudl consider waiting until after the aug ( final distribution, ), so that we would not have to explain where and what was the original remainderman On Tue, Apr 2, 2013 at 5:11 AM, Alan S Halperin <AHalperinfapaulweiss.com> wrote: Multiple and frequent decantings may suggest retained dominion and control. Periodic decantings, spread over years, should not be a problem, provided that the trustees are always involved. 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 (212) 373-3313 (Direct Phone) I (212) 492-0313 (Direct Fax) [email protected] I www,paulweiss.com From: "Jeffrey Epstein" [email protected]] Sent: 04/01/2013 10:56 PM AST To: Alan Halperin as the judah 09 poours into the 97 trust, how much restating or amendments can it have, and if we decant it into a new one , does that effect the grat rules. 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 EFTA_R1_00323920 EFTA01897637 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 EFTA_R1_00323921 EFTA01897638 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 £cc. acationfagmail cam, 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 EFTA_R1_00323922 EFTA01897639 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 jecvacation@gmail,com, 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 jeevacationagmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA_R1_00323923 EFTA01897640