EFTA00991978.pdf

From: Ada Clapp To: jeffrey E. <[email protected]> Subject: RE: Joint Purchase with RL Date: Tue, 01 Jul 2014 22:22:06 +0000 Hi Jeffrey, In the past, Ralph or Withers prepared these joint purchase agreements for Leon. Do you want me to take a stab at it or call Withers? There is one point you noted below that I believe is problematic and that is the right to repurchase at cost. Here is the potential problem: Leon pays $14 million for his 50% interest in the paining—and he gives Ronald the right to purchase it from his estate at $14 million. When Leon dies, his 50% interest in the painting is worth $25 million. His estate will be taxed on $25 million asset but it will only receive $14million from Ronald. Where does it get the additional funds to pay the estate tax? I don't think the contract with Ronald would fix the value for estate tax purposes. Do you think Leon and Ronald meant they would purchase each other's interest at fair market value at the time of death? -Ada From: jeffrey E. [mailto:[email protected] Sent: Tuesday, July 01, 2014 4:48 PM To: Ada Clapp Subject: leon bought a painting with ronald lauder, 50 50 in london, appncprice 28 million total , not uncludnng use tax. on the death of either for six months the survivor can repurchase their interst at cost. each will use it for 2 years and then the other for 2 etc. until death 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 jeevacation®gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00991978