EFTA00823442.pdf

From: "jeffrey E." <[email protected]> To: Reid Hoffman Subject: Date: Tue, 26 Jul 2016 00:02:32 +0000 trust (CRT), where the stock can be sold on a tax-free basis. In addition to avoiding gain recognition, a charitable income tax deduction is available based on the full fair market value of the contributed shares. It is imperative, however, that at the time of the contribution, the inversion transaction is not at the point where the charity receiving the stock is under a legal obligation to surrender the stock. Otherwise, the anticipatory assignment of income doctrine will be applied, so that the donor will be taxed on the transaction, despite donating the shares to charity. To avoid this result, it is best to make the donation of stock before shareholder approval of the inversion occurs. 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 jeevacation®gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00823442