EFTA01969394.pdf

To: jeevacation©gmail.com[[email protected]] From: Fenn, Patrick Sent Fri 6/28/2013 12:59:35 PM Subject: Re: He appreciates that but is focused on timing of TRA payment on preferred (at death) vs TRA payment under current structure (on exchange). Can't separate TRA from preferred and basis step up in preferred only if part of estate. Transfer by estate to private foundation? From: Jeffrey Epstein [mailto:[email protected]] Sent: Friday, June 28, 2013 05:21 AM To: Fenn, Patrick Subject: you might point out to mark that the preferred can achieve the step up. witout the tufts gain trigger, if one dies the esate tax consequnece is funky, tra payment to estate? , no flexibility, 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 Jeffrey Epstein 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 kcyacatiptgiliaitcpm, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved IRS Circular 230 Notice Requirement: This communication is not given in the form of a covered opinion, within the meaning of Circular 230 issued by the United States Secretary of the Treasury. Thus, we are required to inform you that you cannot rely upon any tax advice contained in this communication for the purpose of avoiding United States federal tax penalties. In addition, any tax advice contained in this communication may not be used to promote, market or recommend a transaction to another party. The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. EFTA_R1_00450514 EFTA01969394