EFTA Document EFTA01906372

To: Erika Kellerha From: Jeffrey Epstein Sent: Fri 2/8/2013 8:15:45 PM Subject: Re: Transfer of assets if they both arc sub s for a time, then merged? On Fri, Feb 8, 2013 at 4:02 PM, Erika Kellerhals • wrote: Just to give you a heads up as to where we are. We've run a few different scenarios on getting the assets out of FTC and into STC - and while we have figured out how to contribute the assets in a tax free manner we keep running up against the gain being triggered at the FTC shareholder level thereby not making it eligible for benefits. im going to do a bit more research this weekend - and hope to have it sorted out by Monday. Erika A. Kellerhals Partner 9100 Havensight, Port of Sale Suite 15-16 St. Thomas, U.S. Virgin Islands 00802 Office: Fax: 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 JefTrey 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 c-mail to jecvacationgumail.corn, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA_R1_00339563 EFTA01906372