EFTA00721175.pdf

From: Ada Clapp To: jeffrey E. <[email protected]> CC: Eileen Alexanderson , Lawrence Delson Subject: RE: Split Interest Purchase Date: Mon, 23 Jun 2014 12:43:11 +0000 Yes-but that is all I have this morning. I am working with Alan to put something together for the Trustees to help them decide. Trying to get a break out of the calculation which is based on the June 7520 rate of 2.2% July 7520 rate is the same. Will get back to you when that is sorted out. 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. From: jeffrey E. [email protected]] Sent: Monday, June 23, 2014 8:17 AM To: Ada Clapp Cc: Eileen Alexanderson; Lawrence Delson Subject: Re: Split Interest Purchase incomplete. i need to know what interest rate they used ? On Mon, Jun 23, 2014 at 8:04 AM, Ada Clapp < > wrote: Good morning. See attached. Sent from my iPad Begin forwarded message: From: "Halperin, Alan S" Date: June 13, 2014 at 1:41:19 PM EDT To: "Ada Clapp ( )" EFTA00721175  Cc: "Hurtado, Christopher L" < Subject: Split Interest Purchase I welcome your input. Thanks. Alan IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. Click Hem for More Information Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 19-6064 (Direct Fax) www.paulweiss.com This message is intended only for the use of the Addressee and may contain information that is privileged and confidential. If you are not the intended recipient, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this communication in error, please erase all copies of the message and its attachments and notify us immediately. 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 EFTA00721176