EFTA Document EFTA01954499

To: Jeffrey EpsteinueevacationCOgmail.com] Fran: Alan S Halperin Sent Sun 9/22/2013 12:20:16 PM Subject: Re: Jeffrey, you will recall that the primary concerns with the freeze partnership were: Leon's indirect access to the art would involve the trust and l=b; and if ceased to be a beneficiary, Leon would be forced to pay rent and that rent would be subject to sales tax. Yet, these very concerns would be present if Leon used art as currency when he acquires trust property. The freeze partnership, again, seems superior because it avoids the sales tax issue in connection with the original transaction, and provides a freeze which allows Leon to keep the cashflow for life. Further, once the freeze partnership is in place, we can have transactions with the grantor trust. What am I missing? 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 puny any transaction or matter addressed herein. Alan S. Halperin I Partner Paul, Weiss, Rificind. Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 100194064 ircct Phone) I (Ma (Direct Fax) I•eNelporintiteelembeeeve I www.paulweiss.com From: "Jeffiey Epstein" [email protected]] Seat: 09/22/2013 07:26 AM AST To: Alan Halperin; "Ada Clapp" my argument is that leon is owner for fed income tax purposed of the promissory note, he owns the consideration. and substituties the art. It cannot be recognized for sales taz as he owns the same consideration before and after. its not that there is no consideration it is the ownsership of that consideration did not change. 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 E FTA_R1_00424028 EFTA01954499 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. EFTA_R1_00424029 EFTA01954500