EFTA02620685.pdf

From: Joseph Vinciguerra < Sent: Saturday, October 6, 2018 12:56 PM To: Cc: Brad Wechsler; Barry J. Cohen Subject: RE: 2017 1040 Draft P&C Hi Jeffrey, All K-ls were received timely and are input into the return accordingly. Additionally, all other income and expense items are included in the draft, as I separately track each item to ensure completeness. Please let me know if you need anything else. Joe Joseph M. Vinciguerra I Tax Director & Tax Counsel Elysium Management LLC I 445 Park Avenue Suite 1401, New York, NY 10022 I Te <mailto From: J <[email protected]> Sent: Saturday, October 6, 2018 8:33 AM To: Joseph Vinciguerra < Subject: Re: 2017 1040 Draft P&C when i said issues i mean income items interest expense. facts needed to calculate return seperate from some possible late kls On Fri, Oct 5, 2018 at 9:55 AM Joseph Vinciguerra <mailto >> wrote: I'm not sure what issues being known for months you are referring to. EFTA_R1_01826964 EFTA02620685  • All of the 8621 numbers are Apollo flow through figures, as reported to us on the BRH K•1 and are properly reported, as income from QEF elected PFICS. • What cost of goods sold numbers are you referring to? All reported costs of goods sold are in the proper places on either schedule C, the 8865 or the 8858s. • We discussed your fees regarding the Phaidon loss and opted not to include them in the Phaidon transaction. Note, the amounts paid in 2017 are being deducted as investment related expenses. • There is no net foreign income, based on the allocation of expenses and the BRH related foreign expenses. As such, we are taking the foreign taxes paid as a deduction this year (based on the carryforward). Leon is aware of this and made the decision to deduct. • Debra does not need her own income to contribute to an IRA under the current rules, as Leon has enough wages to cover both contributions. • 965 cfc rules have already been vetted by EY and are no applicable as we have no CFC E&P. • The interest paid is bifurcated between schedules A and E as appropriate, and run through the 4952. Joseph M. Vinciguerra I Tax Director & Tax Counsel Elysium Management LLC I 445 Park Avenue Suite 1401, New York, NY 10022 I Tel. <mailto From: J <[email protected] <mailto:[email protected]» Sent: Friday, October 5, 2018 9:25 AM To: Melanie Spinell »; Joseph Vinciguerra > >; Barry J. Cohen < <mailto Subject: Fwd: 2017 1040 Draft ? all of these issues were known for months? review income numbers flowing through 8621,? cost of good s 10 places show zero. . my fees increase phaidon loss. if leon wants. foreign taxes paid but shows no income? debra is showing an IRA deduction? did she get salary ? . need to check 965 cfc rules this year. . interest cost on approriate schedule? more later. . landing soon. Forwarded message From: Joseph Vinciguerra <mailto >> Date: Fri, Oct 5, 2018 at 9:03 AM Subject: RE: 2017 1040 Draft To: J <[email protected] <mailto:[email protected]» Cc: Barry J. Cohen < <mailto », Brad Wechsler <mailto >> 2 EFTA_R1_01826965 EFTA02620686  Hi Jeffrey, Based on travel schedules, Mrs. Black will be signing the returns on Tuesday and Leon on Wednesday. As such, if you have any comments that could change the return, please let me know, so I can incorporate them, as applicable. Thank you. Joe Joseph M. Vinciguerra I Tax Director & Tax Counsel Elysium Management LLC I 445 Park Avenue Suite 1401, New York, NY 10022 I Tel. <mailto From: Joseph Vinciguerra Sent: Tuesday, October 2, 2018 8:03 PM To: 'J' <[email protected] <mailto:[email protected]» Cc: Barry J. Cohen <mailto >>; Brad Wechsler <mailto >> Subject: RE: 2017 1040 Draft "JEE2017" Joseph M. Vinciguerra I Tax Director & Tax Counsel Elysium Management LLC I 445 Park Avenue Suite 1401, New York, NY 10022 I Tel. <mailto 3 EFTA_R1_01826966 EFTA02620687  From: Joseph Vinciguerra Sent: Tuesday, October 2, 2018 8:02 PM To:T <[email protected] <mailto:[email protected]» Cc: Barry J. Cohen < <mailto »; Brad Wechsler <mailto >> Subject: RE: 2017 1040 Draft Please see attached. Note, I am still working through some immaterial issues with the preparer. Let me know if you have any questions. Password to follow. Joe Joseph M. Vinciguerra I Tax Director & Tax Counsel Elysium Management LLC I 445 Park Avenue Suite 1401, New York, NY 10022 I Tel. <mailto From:1 <[email protected] <mailto:[email protected]» Sent: Tuesday, October 2, 2018 5:51 PM To: Joseph Vinciguerra <mailto Subject: Re: 2017 1040 Draft email On Tue, Oct 2, 2018 at 5:49 PM Joseph Vinciguerra < <mailto > wrote: Hi Jeffrey, 4 EFTA_R1_01826967 EFTA02620688  I hope all is well. I am in the process of finalizing Leon's 2017 1040. Leon would appreciate if you did a high-level review of the draft. Please let me know your delivery preference, as it is over 1,700 pages. Thank you. Joe Joseph M. Vinciguerra I Tax Director & Tax Counsel I Elysium Management LLC I 445 Park Avenue Suite 1401, New York, NY 10022 I Tel. <mailto > please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of 5 EFTA_R1_01826968 EFTA02620689  JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 6 EFTA_R1_01826969 EFTA02620690