EFTA02666754.pdf

From: jeffrey E. <[email protected]> Sent: Sunday, December 11, 2016 9:34 PM To: Karp, Brad S Subject: Re: Fw: Draft Reasonable Cause Statement ACP/AWP Did you speak to him over the weekend? He's not returned text. ?=C240 Unusual On EN, =ec 9, 2016 at 7:08 PM Karp, Brad 5 > wrote: Leon. Brad S. Karp I Partner <=r>Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019-6064 www.paulwe=ss.com =br> EFTA_R1_01918237 EFTA02666754  =br> From: Ok=n, Brad R Se=t: Friday, December 09, 2016 03:20 PM <= class="gmail_msg">Tol Cc:=Karp, Brad S; Brad Wechsler ( 1 .=. •> Subject: Draft Reasonabl= Cause Statement ACP/AWP Leon, as discussed: <1=> Attached are two draft reaso=able cause statements related to the Forms 8865, 8858 and 5471 that we hav= been discussing. The first statement is intended to be used for the 2007-=012 tax years and would be replicated for each year so a separate =tatement is filed with each Form 1040X that is filed. The second statement=is intended to be used for the 2013-2014 tax years. This statement is base= on the first but contains some differences in the background paragraph, w=ich reflect the fact that (i) the K-1 provided for those years exp=icitly stated that no foreign filings were required and (ii) notwithstandi=g the footnote, a Form 8865 was in fact filed for BRH for 2013 and 2014. T=e attached pdf redline highlights the changes between the two stat=ments. 2 EFTA_R1_01918238 EFTA02666755  <= class="MsoNormal gmail_msg"> <=p> Let me know if you would like to discuss. This message is i=tended only for the use of the Addressee and may contain information that =s privileged and confidential. If you are not the intended recipient, you=are hereby notified that any dissemination of this communication is strict=y prohibited. If you have received this communication in error, please er=se all copies of the message and its attachments and notify us immediately= 3 EFTA_R1_01918239 EFTA02666756