EFTA02672196.pdf

From: Ada Clapp < Sent: Monday, November 18, 2013 4:05 PM To: Eileen Alexanderson; Jeffrey Epstein; Richard Joslin Subject: Split-Dollar Proposal Attachments: 11.18.13 Split-Dollar Proposal.pptx; Untitled attachment 00746.htm Please =ee the attached revised split-dollar proposal pursuant to discussions =ith Carlyn this morning. Elyse is summarizing the proposal in a =emorandum for Leon. Rich—at our meeting you =xpressed concerns that the proposal would generate a gift or income tax =iability. If you are still concerned, would you please summarize =hose concerns for inclusion in Carlyn's memorandum to Leon. As =ou saw from her earlier emails, Carlyn sees the only risk as a gift tax =isk resulting from an incorrect valuation on the purchase of AIF IV =rom Leon. I think we should also discuss any concerns you have =ith Carlyn before going to Leon with the =Ian. Thanks! Ada Clapp Black Family =artners go Apollo Management 9 W 57th Street New =ork NY 10019 phone: 917-286-5536 email: IRS Circular 230 =isclosure: Pursuant to IRS regulations, I inform you =hat any tax advice contained in this communication (including =ttachments) is not intended or written to be used, and cannot be used =y any person or entity for the purpose of (i) avoiding tax related =enalties imposed by any governmental tax authority, or (ii) promoting, =arketing or recommending to another party any transaction or matter =iscussed herein. I advise you to consult with an independent tax =dvisor on your particular tax circumstances. This =ommunication, and any attachment, is for the intended recipient(s) only =nd may contain information that is privileged, confidential and/or =roprietary If you are not the intended recipient, you are hereby =otified that further dissemination of this communication and its =ttachments is prohibited. Please delete all copies of this =ommunication and its attachments and notify me immediately that =ou have received them in error. EFTA_R1_01945045 EFTA02672196