EFTA02478339.pdf

From: jeffrey E. <[email protected]> Sent: Tuesday, December 8, 2015 5:19 PM To: Halperin, Alan S Subject: Re: Phaidon Transaction 267 b4 says truestee of grantor. . =the above ruling says two trustees ? are you=certain wrote: The attached ruling addresses Section 267(b)(5), which provides tha= if two trusts are established by the same grantor, their fiduciaries are =elated to each other. The IRS ruled that, in making the fiduciaries related to each other, the statute refers only t= their official actions as trustees of the common grantor's trusts= not to transactions involving their personal assets or other trusts under=their administration. Accordingly, if an individual, in his individual capacity, is buying an asset, 267 should =ot apply, even if that individual otherwise is a trustee of non-selling tr=st. Thus, Richard need not resign as Trustee of the other trusts. Al=n </=pan> Alan=S. Halperin Part=er Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019-6064 www.paulweiss.com <http://www.paulweiss.com> This message is intended only fo= the use of the Addressee and may contain information that is privileged a=d confidential. If you are not the intended recipient, you are hereby not=fied that any dissemination of this communication is strictly prohibited. =If you have received this communication in error, please erase all copies =f the message and its attachments and notify us immediately.=/p> please =ote The information contained in this communication is confiden=ial, may be attorney-client privileged, may constitute inside informati=n, and is intended only for the use of the addressee. It is the propert= of JEE Unauthorized use, disclosure or copying of this communica=ion or any part thereof is strictly prohibited and may be unlawful. If =ou have received this communication in error, please notify us immediat=ly by return e-mail or by e-mail to [email protected] <mailto:jeevacation@gmail=com> , and destroy this comm=nication and all copies thereof, including all attachments. copyright -=11 rights reserved EFTA_R1_01592830 EFTA02478339