EFTA Document EFTA01941123

To: Richard Joslin Cc: jemeationegmail.com[jeevacation©gmail.com] From: Fenn, Patrick Sent Thur 1/30/2014 12:56:10 AM Subject: RE: proposed regs -752/707 Eli Richard. These are on my weekend reading list. I hadn't heard about the retroactive aspect. When they did that a few years back with the 267 matching rules, they got their hands slapped. Thanks and regards From: Richard Joslin Sent: Wednesday, January 29, 2014 7:23 PM To: Fenn, Patrick Cc: [email protected] Subject: proposed regs -752/707 Fyi I have not read — the effective dates are when finalized — looking at the effective date provisions- t parts of the 752 regs arc retroactive to 2006 and the 707 regs back to 1991. As a follow up to our prior discussion. IRS Circular 230 Notice Requirement: This communication is not given in the form of a covered opinion, within the meaning of Circular 230 issued by the United States Secretary of the Treasury. Thus, we are required to inform you that you cannot rely upon any tax advice contained in this communication for the purpose of avoiding United States federal tax penalties. In addition, any tax advice contained in this communication may not be used to promote, market or recommend a transaction to another party. The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. EFTA_R1_00399815 EFTA01941123