EFTA Document EFTA01910521

To: Erika Kellerhals From: Jeffrey Epstein Sent: Fri 1/4/2013 1:38:57 PM Subject: Re: so what structure would work, for the bank? do i , or do they own the cumalitve preferred, ? what limits , how do they get a tax deferral with little risk On Fri, Jan 4, 2013 at 8:51 AM, Erika Kellerhals < wrote: If you own bulk of cs its okay Also depends on types of income company is generating Active vs non-active income Erika A. Kellerhala Partner Kellorhals Ferguson Fletcher Kroblin LLP Notice: This communication may contain privileged or other confidential information. If you are not the intended recipient. or believe that you have received this communication in error. p'ease do not print. copy. re-transmit. disseminate. or otheninse use this information. Also. please Indicate to the sender that you have received this e-mail in error. and delete the copy you received. Thank you. Circular 230: To ensure compliance with the requirements imposed by the IRS. we inform you that any tax advice contained in our communication (including any attachments) was not intended or •written to be used. and cannot be used. for the purpose or 0) avoiding any tax penalty or re) promoting. marketing or recommending to another party any transaction or matter addressed herein. From: Jeffrey Epstein <[email protected]> Date: Friday, January 4, 2013 8:49 AM To: Erika Kellerhals Subject: Re: so if us residents own common shares in our new bank,? why is my holding of a 100 percent intrest as a us person not included, On Fri, Jan 4, 2013 at 8:32 AM, Erika Kellerhals wrote: EFTA_R1_00346573 EFTA01910521 An entity incorporated in the USVI is considered a foreign corporation for the purposes of the unmirrored Internal Revenue Code. Therefore, when U.S. shareholders control a USVI corporation under the 50% rule ( U.S. shareholders own more than 50% of the combined voting power of its stock or more than 50% of the total value of the stock) the USVI corporation is treated as a CFC (a "USVI CFC"). To the extent that a USVI CFC invests its earnings in United States property or earns subpart F income in the form of foreign base company sales income, foreign base company services income, or foreign personal holding company income, its United States shareholders are taxed on such investment in United States property and subpart F income to the same extent as if such corporation were formed in a foreign country Erika A. Kellerhals Partner KeHornets Ferguson Fletcher Kroblin LLP Notice: This communication may contain privileged or other confidential information. If you are not the intended recipient. or believe that you have wend this communication in error. please do not print. copy. re-transmit. disseminate. or otherwise use this information. Also. please indicate to the sender that you have received this e-mail in error, and delete the copy you received. Thank you. Circular 230: To ensure compliance with tho requirements imposed by the IRS. wo inform you that any tax advice contained in our communication (including any attachments) was not intended or written to be used. and cannot be used. for the purpose of (i) avoiding any tax penalty or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. From: Jeffrey Epstein <[email protected]> Date: Thursday, January 3, 2013 7:00 PM To: Erika Kellerhals Subject: <no subject> how do the cfc rules apply to us residents holding shares in vi corp. 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 EFTA_R1_00346574 EFTA01910522 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 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 *********************************************************** 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 iccvacation0 umail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA_R1_00346575 EFTA01910523