EFTA02668353.pdf

From: Richard Kahn < Sent: Saturday, November 26, 2016 3:40 PM To: Jeffrey Epstein Subject: Re: EDC Memorandum - EAK actuals i will do monday or tuesday (need 5-6 hours without =istractions) doctors are crazy..they should be penalized for all the =ggravation they cause from their sloppiness.. Richard Kahn HBRK Associates Inc. 575 =exington Avenue, 4th Floor New =ork, NY 10022 On Nov 26, 2016, at 10:36 AM, jeffrey E. <[email protected]> wrote: thx.. and when can i get acturals for our cash =low. ? btw on fri on monday they said it was a typo =hat should have read a non- substantial. can you =elive it On Sat, Nov 26, 2016 at 10:34 AM, =ichard Kahn < > wrote: i calculated the additional =ost of not having EDC benefits to be 891,000. Note that the two =ariables are that i am estimating Boothbay & Honeycomb ordinary =ncome which are difficult to determine year to year. I calculated that =ou will have 2,500,000 of EDC income in 2016 which is comprised of =oreign corporation interest and dividends, foreign currency trades, =edge funds (booth bay, haze & honeycomb) and STC operating =xpenses. capital gains will be offset by capital loss carry =orward of 35mm. Calculation Max ordinary US rate =nbsp; 39.6% EDC rate =nbsp; 3.96% Tax savings with EDC benefits 35.64% 2,500,000 x 35.64% = =91,000 Richard =ahn EFTA_R1_01920432 EFTA02668353  HBRK Associates Inc. 575 Lexington Avenue, 4th Floor New York, NY 10022 On Nov 26, 2016, at 12:50 AM, jeffrey E. <[email protected]> wrote: that wasnt my question. I =m aaware . of erika memo. question was is there a =oney difference On Fri, Nov 25, 2016 at 8:36 PM, =ichard Kahn < > wrote: i believe that you will still =ualify under 3 year average test per Erika memo attached: Physical =resence Test For taxable =ears ending after January 31, 2006, Treasury Regulation § 1.937-1(c), as amended =n November 14, 2006, provides that a U.S. citizen or resident alien satisfies the =hysical presence test if he or she meets one of five alternative tests: • 183-Day Test: =/span>First, an individual can satisfy the strict 183-day rule codified in Code section 937, that =s, spend at least 183 days a year in a possession including days of =ravel to and from a possession as long as part of the day of travel is spent =n a possession. • Three-Year Average Test: =econd, an individual can satisfy the physical presence test by being present in a possession for at =east 549 days during a three-year period consisting of the current taxable =ear and the two immediately preceding taxable years, provided that the =ndividual is also present in the possession for at least 60 days during each =axable year of the three-year period. In other words, this alternative to the physical presence test =equires an individual to be present in a possession for a simple nonweighted three-year average of 183 days per year so long as a minimum of 60 days of presence is met in each of those three years. 2 EFTA_R1_01920433 EFTA02668354  • No More Than 90 Day Test: =/span>Third, an individual can satisfy the physical presence test by spending no more than 90 days =n the United States each year. • More Time in a Possession and Earned Income Not Exceeding $3,000 =est: Fourth, an individual can satisfy the physical presence test by spending more days in a possession than =n the United States and having earned income[1J in the United States not exceeding $3,000. * No Significant Connection to the United States Test: Fifth, =n individual can satisfy the physical presence test by having no significant connection to the =nited States. However, this exception may not encompass any individual who has full-time access to any =esidence in the United States even if the residence has never been the =ndividual's tax home, such as a vacation home. (1] U.S. earned =ncome is defined in the regulations by reference to Treasury Regulation § 1.911.3(b)= which deals with the foreign earned income exclusion for citizens or residents =f the United States living abroad. Under this section "earned =ncome" is composed of wages, salaries, professional fees and other amounts received as =ompensation for personal services actually rendered. Professional fees constitute earned income even if the individual employs assistants to perform part or all of the services, provided that =he clients are those of the individual and look to the individual as the =erson responsible for the services rendered. "Earned income" does not include a distribution of =arnings and profits by a corporation. Earned income, however, may include wages paid by a possession entity that are paid to =n employee for business travel in the United States. i will review test with erika and economic with =eanne.. Richard Kahn HBRK Associates Inc. 575 Lexington Avenue, 4th Floor New York, NY 10022 Begin forwarded message: From: =/b>"Jeanne" < 3 EFTA_R1_01920434 EFTA02668355  Subject: =/b>EDC Memorandum - =AK Date: =/b>September 30, 2015 at 4:15:41 PM =DT To: =/b> >, "'Alan Dlugash'" Cc: = please note The information contained in this =ommunication is confidential, may be attorney-client =rivileged, may constitute inside information, and is =ntended only for the use of the addressee. It is the =roperty of JEE Unauthorized use, disclosure =r copying of this communication or any part thereof is =trictly prohibited and may be unlawful. If you have =eceived this communication in error, please notify us =mmediately by return e-mail or by e-mail to [email protected], and destroy this =ommunication and all copies thereof, including all =ttachments. copyright -all rights reserved please =ote The information contained in this =ommunication is confidential, may be attorney-client =rivileged, may constitute inside information, and is =ntended only for the use of the addressee. It is the =roperty of JEE Unauthorized use, disclosure =r copying of this communication or any part thereof is =trictly prohibited and may be unlawful. If you have =eceived this 4 EFTA_R1_01920435 EFTA02668356 communication in error, please notify us =mmediately by return e-mail or by e-mail to [email protected], and destroy this =ommunication and all copies thereof, including all =ttachments. copyright -all rights reserved 5 EFTA_R1_01920436 EFTA02668357