EFTA02566001.pdf

From: Alan S Halperin Sent: Wednesday, February 20, 2013 1:22 PM To: Jeffrey Epstein; Carlyn S. McCaffrey Subject: Re: Fwd: Narrows Perhaps. On the other hand, there are risks. I =elieve I gave you a cite to an advisory opinion in which it was determined==hat a corporation, wholly owned by one stockholder, failed the Moline =roperties test. The corporation owned a boat that was docked part of==he year in NY. The court disregarded the corporate entity and =ubjected the stockholder to use tax. In our case, I believe, there =s one member of the LLC, that member also is the manager with full =uthority, the member has the right to withdraw at any time, the LLC's =ssets are personal use assets (many of which are hanging on his wall), and==he LLC guaranteed the payment of the member's loans. It would not be a =tretch for the NY taxing authorities to asset that a sales tax is due unde==Moline Properties. We must consider this risk among the many factors in =omparing the various planning =trategies. IRS Circular 230 =isclosure: To ensure compliance with requirements imposed by the IRS, w==inform you that any U.S. federal tax advice contained in this communicatio==(including any attachments) is not intended or written to be used, and =annot be used, for the purpose of (i) avoiding penalties under the Interna==Revenue Code or (ii) promoting, marketing or recommending to another party==ny transaction or matter addressed herein. Alan S. Halperin I =artner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue =f the Americas I New York, NY 10019-6064 (Direct Phone) ==(212) 492-0313 (Direct Fax From: =/b>"Jeffrey Epstein" ([email protected] Sent: =/b>02/20/2013 06:19 AM EST To: Alan Halperin; Subject: Fwd: =arrows here you have pretty good evidence of a biz purpose unrelated to this =ransfer, transfer of Ilc interest for partnership =nterest. .. if not today , we can put some other =nvestments into narrows, and reserve the opportunity for later. Forwarded message - From: Eileen Alexanderson Date: Tue, Feb 19, 2013 at 6:19 PM Subject: Narrows To: "Jeffrey==pstein ([email protected])" =It;[email protected]> EFTA_R1_01730938 EFTA02566001  Ori: inal Messa:e From: Sent: Tuesday, February 19, 2013 6:12 PM To: Eileen Alexanderson Subject: Scan from a Xerox Color Please open the attached document. It was scanned and sent to you =sing a Xerox Color. Number of Images: 37 Attachment File Type: PDF Device Name: NY_730_11_XRX_COPYROOM Device Location: For more information on Xerox products and solutions, please visit http://www.xerox.com/ This email and any files transmitted with it are confidential and intended solely for the person or entity to whom they are addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other than the intended recipient is prohibited. If you have received this email in error please contact the sender and delete the material from any computer. Apollo Global Management, LLC =br> The =nformation contained in this communication is confidential, may be =ttorney-client privileged, may constitute inside information, and is =ntended only for the use of the addressee. It is the property of Jeffrey Epstein =br>Unauthorized use, disclosure or copying of this communication or any==art thereof is strictly prohibited and may be unlawful. If you have =eceived this communication in error, please notify us immediately by return e-mail or==y e-mail to [email protected] <mailto:[email protected]> , and destroy this =ommunication and all copies thereof, including all attachments. copyright -all rights reserved This message is intended only for the use of the Addressee and==ay contain information that is privileged and confidential. If you are not th==20 intended recipient, you are hereby notified that any dissemination of this=20 communication is strictly prohibited. If you have received this =ommunication in error, please erase all copies of the message and its attachments and notify us immediately. 2 EFTA_R1_01730939 EFTA02566002