EFTA00868628.pdf

From: Richard Kahn To: "Jeffrey E." <[email protected]> Subject: Fwd: pilots Date: Thu, 06 Nov 2014 19:39:49 +0000 Attachments: N624N P9I MGMT AGMT_REX-c.pdf Inline-Images: profile_mask_2x.png; cleardot.gif why did leon sign without your review / comments? apollo not using leon plane seems strange - were other partners planes used? plane is clearly to expensive for jet aviation to manage for 200 hours per year.. joslin clearly has no handle on this yet he and larry delson met with experts back in June 2014 per emails below: From: Richard Joslin Subject: RE: Aviation: use of G-V by PE partner, 135/ 91, 280F, 167, excise tax, charter v reimbursement etc Date: June 4, 2014 at 3:36:41 PM EDT To: Richard Kahn , Cc: Idelson I will send more detailed bullet list later today — I was hoping to send sooner but I have been sidetracked on decanting and appraisal work As there will be 3 partners I did not ask them to review all the Avionetta documents and I set up the meeting with short notice as an introduction and an overview of the FAA/tax issues • Use of G-V by PE partner - trade or business status by partner: structuring ownership o/s of management company (FY 2012 and 2013) • 135/ 91 - understand how flying under each is to be undertaken if there is reimbursement vs charter (airport is 135 vs airport 91) • 280F/ 167 - plane depreciation — can these rules be avoided if plane is leased to charter operator who charters back to owner. • Excise tax — observed in breach or paid. 91 vs 135 • Charter under 135 vs reimbursement under 91 vs reimbursement under 135. Understand the differences if the plane is not chartered out • Cost > than reimbursement/ charter From: Richard Kahn Imailto Sent: Wednesday, June 04, 2014 3:20 PM To: Richard Joslin Cc: Idelson Subject: Re: Aviation: use of G-V by PE partner, 135/ 91, 280F, 167, excise tax, charter v reimbursement etc EFTA00868628 as per jeffrey i am going to attend tomorrow meeting at 10:30 can you please confirm location? in addition will you provide list of issues and facts today for review? please advise thank you Richard Kahn HBRK Associates Inc. 575 Lexington Avenue 4th Floor New York, NY 10022 tel fa ce On May 30, 2014, at 12:40 PM, Richard Joslin > wrote: I will look to provide advance list of issues and current facts Ruth Wimer (tax) David DeYoe (FM). McDermott Will & Emery LLP 1 340 Madison Avenue I New York, NY 10173-1922 Tel Richard Joslin CFO Elysium Management LLC 445 Park Ave Ste. 1401 New York, NY 10022 (w) (c) (0 From: "jeffrey E." <[email protected]> Subject: airplane expert Date: May 29, 2014 at 11:27:57 AM EDT To: Richard Kahn < , Richard Joslin EFTA00868629 carlyn suggests Jay Rivlin in our NY Office does a lot of this work. Here's a link to his contact information. Richard Kahn HBRK Associates Inc. 575 Lexington Avenue 4th Floor New York, NY 10022 tel fa) ce Begin forwarded message: From: Richard Joslin Subject: pilots Date: November 6, 2014 at 2:07:38 PM EST To: Jeffrey E. <[email protected]> Cc: "Richard Kahn ( r an When I quoted you 3 pilots, I quoted from the Jet Aviation contract —see part IV Flight Support Personnel. Note in the January 2014 invoice I sent to you earlier today, there were 3 pilots for the trip to St Thomas 12/22/2013 — 1/2/2014. All other flights for 201 through Aug 2014 have two pilots. EFTA00868630