EFTA00968760.pdf

From: Erika Kellerhals To: Jeffrey Epstein <[email protected]> Subject: Re: ESBT Date: Mon, 26 Aug 2013 12:13:12 +0000 My understanding of esbts is fairly limited but I believe funding is a gift. Each beneficiary is considered a shareholder so subject to the same rules as with s corps re: us citizen etc. trust is taxed at highest rate even if no distributions. Income of trust not reduced to expenses. Distributions to benes tax-free. I also believe you have to fund it with a gift. Sent from my iPhone On Aug 26, 2013, at 6:44 AM, "Jeffrey Epstein" <[email protected]> wrote: here is my question. it appears that esbts can hold s stock, have more than one shareholder. the trust pays tax at the max rate and then the other shareholders appear to receive tax -free income. ? the regs stress max tax rate . so that the income is only taxed once. ? i don;t know if funding it is a gift? , On Mon, Aug 26, 2013 at 6:41 AM, Erika Kellerhals < > wrote: Great. I have about 30 min at 11am so ill dial in. Sent from my iPhone On Aug 25, 2013, at 6:49 PM, "Jeffrey Epstein" <[email protected]> wrote: -------- Forwarded message From: Fenn, Patrick 4 Date: Sun, Aug 25, 2013 at 6:44 PM Subject: Re: ESBT To: "jeevacation®gmail.com" <[email protected]> Jeffrey, Let's use this as a dial in for tomorrow's call at 11M. EDT: Toll-Free Dial-In Number: (800) 705-9024 Intl Access/Caller Paid Dial-In Number: +1 913 904 9887 EFTA00968760 Access Code: 872 8185 From: Jeffrey Epstein [mailtoleeyacationegmail.corn Sent: Friday, August 23, 2013 06:50 AM To: Fenn, Patrick Subject: Re: ESBT monday fine On Thu, Aug 22, 2013 at 11:36 PM, Fenn, Patrick > wrote: Hi Jeffrey. A couple of my trust and estates partners are familiar with the ESBT. Let me know if you want me to set up a call and when. Tomorrow might be difficult for them but they will be available early next week. Best regards IRS Circular 230 Notice Requirement: This communication is not given in the form of a covered opinion, within the meaning of Circular 230 issued by the United States Secretary of the Treasury. Thus, we are required to inform you that you cannot rely upon any tax advice contained in this communication for the purpose of avoiding United States federal tax penalties. In addition, any tax advice contained in this communication may not be used to promote, market or recommend a transaction to another party. The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. 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 Jeffrey Epstein 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 IRS Circular 230 Notice Requirement: This communication is not given in the form of a covered opinion, within the meaning of Circular 230 issued by the United States Secretary of the Treasury. Thus, we are required to inform you that you cannot rely upon any tax advice contained in this communication for the purpose of avoiding United States federal tax penalties. In addition, any tax advice contained in this communication may not be used to promote, market or recommend a transaction to another party. The information contained in this e-mail message is intended only for the personal and EFTA00968761  confidential use of the recipients) named above. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. *********************************************************** 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 Jeffrey Epstein 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 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 Jeffrey Epstein 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 EFTA00968762