EFTA Document EFTA01954349

To: Melanie Spinell From: Jeffrey Epstein Sent: Sun 9/29/2013 5:23:48 PM Subject: Fwd: Pour-over and GRATs now six weeks old Forwarded message From: Alan S Halperin < Date: Fri, Sep 27, 2013 at 10:00 AM Subject: Re: Pour-over and GRATs To: Ada Clapp -EIMI=Mil Cc: Eileen Alexanderson < <jeevacatioOcumail.com>, Jessica Soojian , Jeffrey Epstein Suppose the GRAT pours over into one of the existing trusts, say the 1997 Trust. When the Heritage Trust eventually is ready, the Trustee of the 1997 Trust will decant into the Heritage Trust. That decanting could include not only the assets held at that time, but any future receipts. I need to review the documentation by which Leon acquired his BFP interest from the 2006 Trust to see if we need to address any restrictions. I will revert. Jeffrey, how much is Leon transferring? 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, Rifkind, Wharton & Garrison LLP From 'Ada Clapp' To 'Jeffrey Epstein' c•oovacatwn^m malt cam> Cc 'Melanie Spinella"Eileen Alexanderson" Halperin/PaulWetsvaPaulWeiss Alan S EFTA_R1_00423805 EFTA01954349 Date: 09/27/2013 09:52 AM Subject: Re: Poueover and GFtATs Good morning Jeffrey, I understand that you want to move quickly (though perhaps not all the nuances for your timing) but I am wondering whether we have thoroughly considered the timing of the pour-over? Does it perhaps makes sense to do the pour-over gerr you have received a favorable advisory opinion on the substation for your client and we decide how to move forward with Leon's substation. Two reasons to consider waiting for your client's ruling: I. If we do the substation in the 2006 Trust (which will disappear), what gets decanted into the Heritage Trust is the art. Nice and clean --no need to do a substitution in the Heritage Trust that might draw attention if we decide to move forward on someone else's ruling. 2. The substitution language cited in the petition for the ruling request is the Weil language contained in the 2006 Trust. The Heritage Trust contains different substitution language. We don't know how much the language will factor into the Advisory Opinion. Might make it harder to rely on someone else's opinion if we decide to move forward on that basis. What do you think? Ada Clapp Slack Family Partners Go Apollo Management 9 W 57th Street New York NY 10019 IRS Circular 230 Disclosure: Pursuant to IRS regulations, I inform you that any tax advice contained in this communication (including attachments) is not intended or written to be used, and cannot be used by any person or entity for the purpose of (i) avoiding tax related penalties imposed by any governmental tax authority, or (ii) promoting, marketing or recommending to another party any transaction or matter discussed herein. I advise you to consult with an independent tax advisor on your particular tax circumstances. This communication, and any attachment, is for the intended recipient(s) only and may contain information that is privileged, confidential and/or proprietary If you are not the intended recipient, you are hereby notified that further dissemination of this communication and its attachments is prohibited. Please delete all copies of this communication and its attachments and notify me immediately that you have received them in error. EFTA_R1_00423806 EFTA01954350 On Sep 27, 2013, at 9:11 AM, Jeffrey Epstein <[email protected]> wrote: lets prepare the new grats and pourover asap. 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 copics 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 EFTA_R1_00423807 EFTA01954351 return e-mail or by e-mail to ice\ [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA_R1_00423808 EFTA01954352