📄 Extracted Text (405 words)
From: "Jeffrey E." <[email protected]>
To: Ada Clapp
Bee: Melanie Spinella
Subject: Re: Ben's $1.5 Million Loan
Date: Thu, 28 Jan 2016 14:41:14 +0000
agree„ but check with leon
On Thu, Jan 28, 2016 at 9:40 AM, Ada Clapp c > wrote:
Good morning Jeffrey,
If I understood you correctly, as part of the intra-family Note clean-up, you suggested that the Trustees of
APO-01 Declaration consider forgiving the $1.5 million Note from Ben that they hold. If that is correct, I
would like to suggest an alternate approach to eliminating Ben's Note (it is the same approach we used for
Ben's $10 million distribution at age 30). That is:
1. The APO-01 Declaration would pay down some of the Note given to the BEB 2011 Trust when
that trust sold its interest in the LDB 2011 LLC. The pay-down amount would equal the
outstanding principal and accrued interest of Ben's Note held by the APO-01 Declaration.
2. The BEB 2011 Trust would then distribute the funds it just received to Ben; and
3. Ben would use the distribution to repay the APO-01 Declaration the outstanding principal and
interest on the $1.5 million Note.
This approach allows us to reduce some intra-family debt and does not increase anyone's taxable estate.
Please let us know if you agree with this approach and we will put it in motion.
Thanks.
Ada Clapp
Chief Legal Officer
Elysium Management LLC
445 Park Avenue
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