EFTA Document EFTA01990704

To: [email protected]]; [email protected][[email protected]] Cc: Staley, Jes From: Erdoes, Mary Sent: Fri 8/26/2011 1:43:38 AM Subject: In answer to the tax ruling question you asked today We will need to file an application (a Form 1023) with Treasury/IRS to create and receive approval of tax exempt status for the new organization. while this is a normal application process, we will probably get special scrutiny due to the names involved and the fact that this is likely one of the first `commercial' DAF applications since the IRS crackdown on perceived DAF abuses and related legislation passed in 2006. Mary This email is confidential and subject to important disclaimers and conditions including on offers for the purchase or sale of securities, accuracy and completeness of information, viruses, confidentiality, legal privilege, and legal entity disclaimers, available at http://www.jpmorgan.com/pages/disclosures/email. EFTA_R1_00483397 EFTA01990704