EFTA00983931.pdf

From: Jeffrey Epstein <jeevacation®gmail.com> To: Richard Joslin Subject: Re: Decanting the 1997 trust to APO2 Date: Tue, 25 Feb 2014 19:16:43 +0000 did you send me the phila file? On Tue, Feb 25, 2014 at 3:08 PM, Richard Joslin < > wrote: Thanks for the quick response - We will get a new tax ID for this trust. There has not been consistent tax reporting in the past (some file 1041 and some not). I will move to have uniform reporting for the grantor trusts Original Message----- From: Ada Clapp Sent: Tuesday, February 25, 2014 1:53 PM To: Richard Joslin Cc: Eileen Alexanderson; Jeffrey Epstein; Richard Subject: RE: Decanting the 1997 trust to APO2 Rich-I am indifferent as to whether you report the income of grantor trusts using Leon's tax ID number or a separate EIN you get for the trusts. I think you just need to be consistent. Ada Clapp Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022 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. Original Message----- From: Richard Joslin Sent: Tuesday, February 25, 2014 1:44 PM To: Ada Clapp Cc: Eileen Alexanderson; Jeffrey Epstein; Richard Subject: RE: Decanting the 1997 trust to APO2 EFTA00983931  As I understand this decanting, the distributing trust and receiving trust are both grantor trusts and have the same owner before and after. As such the receiving trust is a continuation of the distributing trust, ie same tax ID number for income tax purposes. While two assets may have negative tax basis in 2014 (Blue Sunshine had negative tax basis alo 12/31/2012 of $(300K); AP Energy Partners LLC had a negative tax basis alo 12/312012 of $(10K) - we do not have K-1's FY 2013), the decanting should not trigger any gain on transfer. On a related vein, I'd like to get Ada/Alan input on not using LDB SSN for the grantor trusts and getting EIN's and reporting annually Form 1041 with trust letter. I would like to have annual 1041 filing for the trusts vs no reporting other than included on 1040 directly. Original Message----- From: Ada Clapp Sent: Tuesday, February 25, 2014 8:33 AM To: Richard Joslin; Richard Cc: Eileen Alexanderson; Jeffrey Epstein Subject: Decanting the 1997 trust to APO2 We are planning to send the Decanting Notice to the beneficiaries of the 1997 trust today. Just checking to be sure there are no tax or other issues for our accounting team. If so, please let me know as soon as you can. Thanks. Sent from my iPad 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 [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00983932