EFTA02454259.pdf

From: jeffrey E. <[email protected]> Sent: Wednesday, August 24, 2016 12:35 AM To: William Blum; Erika Kellerhals Subject: Re: Trust Project, etc. when will you have the draft. we need a fully =xamined bill ready by third week of sept? On Tue, Aug 23, 2016 at 5:43 PM, William=Blum » wrote: Dear Jeff — We are hard at work o= this project. I spoke with Governor Mapp about ten days ago and als= I might see him when I am on island early next week.=/p> Attached for your review and comment is our memo constituting the first=part of our analysis regarding the possibility of establishing the VI as a=jurisdiction where large US corporations could move their asset holding su=sidiaries presently located in other foreign jurisdictions such as Ireland=or other offshore locations such as Bermuda, BVI, Cayman, Channel Islands,=etc. The focus of the memo is on IRC sections 367 and 1248. Phase review and let us know if you have any questions.=/p> In the meantime, I am cleaning up the draft statutory trust legislation=prepared for the Governor by Peter Hiebert. Peter's draft of=this legislation was lifted directly from Delaware (which is good).=C2 The initial changes I am making relate to putting it in proper VI le=islative form, as well as making substantive changes to adopt provisions o= the law of other jurisdictions (or new provisions) that are more favorabl= than those of Delaware. Asset protection is the main focus there an= the jurisdictions we are primarily looking at in this regard are South Da=ota, Alaska, New Hampshire, Nevada, and Cayman Islands. Also, we are tryin= to work out a method by which the tax exemption for these entities will b= automatic for some purposes/owner, i.e., no approval of an agency such as=the EDC required; rather the exemption would be statutory if requirements =re met like with USVI exempt companies. The tax exemptions will be f=r certain purposes, such as for use in structured finance transactions or =here the beneficial owners are foreign, but we also need to draft some lim=tations so that the we can avoid unintended or abusive use of the entities= =/span> I shall be back in touch when I have more =o report or a draft to share. Fax Email 1. EFTA_R1_01555887 EFTA02454259  plea=e note The information contained in this communication is confi=ential, may be attorney-client privileged, may constitute inside inform=tion, and is intended only for the use of the addressee. It is the prop=rty of JEE Unauthorized use, disclosure or copying of this commun=cation or any part thereof is strictly prohibited and may be unlawful. =f you have received this communication in error, please notify us immed=ately by return e-mail or by e-mail to [email protected] <mailto:jeevacation@gm=il.com> , and destroy this c=mmunication and all copies thereof, including all attachments. copyrigh= -all rights reserved 2 EFTA_R1_01555888 EFTA02454260