EFTA00990432.pdf

From: "Jeffrey E." <[email protected]> To: Eileen Alexanderson Subject: Re: FW: APO1 GRAT No. 4 Date: Fri, 30 May 2014 20:23:15 +0000 4th ok On Fri, May 30, 2014 at 2:48 PM, Eileen Alexanderson < > wrote: I asked Ada to leave the assignment undated so we have flexibility to do this at any point while Leon is away rather than being locked into the 4th (though the 4th is preferable from the standpoint of the related valuation work) From: Ada Clapp Sent: Friday, May 30, 2014 2:43 PM To: Eileen Alexanderson Cc: Richard Joslin; Richard D'Agostino; Jeffrey E. Subject: APO I GRAT No. 4 Alan is sending me the execution copy of the APOI GRAT No. 4 for Leon to sign before he leaves on Monday. Please let me know if I should send it to Leon's office or the house and whether I also need to send Elizabeth to act as notary. Leon can sign the GRAT Agreement today--and have it notarized as of today. The Agreement will indicate that it is to be effective as of June 4th when it the GRAT is to be funded. The Assignment Agreement for the gift into GRAT 4 will be dated (and effective) June 4th so that will be the start date of the GRAT term. The gift in to GRAT 4 will generate a taxable gift of $47 per million contributed. Thanks! Ada Clapp Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022 EFTA00990432  Direct Dial: Fax: Email: IRS Circular 230 Disclosure: Pursuant to IRS regulations, I inform you that any tax advice contained in this communication (including attachments) is not intended or written to be used, and cannot be used, by any person or entity for the purposes of (i) avoiding tax related penalties imposed by any governmental tax authority, or (ii) proposing, marketing or recommending to another party any transaction or matter discussed herein. I advise you to consult with an independent tax advisor on your particular tax circumstances. This communication and any attachment is for the intended recipient(s) only and may contain information that is privileged, confidential and/or proprietary. If you are not the intended recipient, you are hereby notified that further dissemination of this communication and its attachments is prohibited. Please delete all copies of this communication and its attachments and notify me immediately that you have received them in error. Thank you. 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], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00990433