EFTA00979163.pdf

From: Jeffrey Epstein <[email protected]> To: Alan S Halperin <I Subject: Re: Fwd: ART Rent Date: Thu, 19 Dec 2013 12:50:09 +0000 what if debra immedialty buys a membership interest in the Ilc On Thu, Dec 19, 2013 at 7:44 AM, Alan S Halperin < > wrote: Please consider the following: 1. If art is owned directly, rather than through an LLC, envelope the art currently held by the 2011 LLC in a separate LLC (the "Art LLC"). 2. Distribute membership interests in the Art LLC to the four 2011 trusts. 3. After you get your sales tax ruling, Leon substitutes a note for the Art LLC membership interests. 4. Thereafter, Leon -- who then owns the Art LLC, substitutes that interest with APO1 in exchange for reducing the note. 5. Since Debra is a beneficiary of APO1, there is no rent payment. Instead, the trustees enter into a use agreement. All of this will take some time to implement. Significantly, I would not proceed until your have your ruling. Also, will need to get the trustees, including US Trust, on board. 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 Here for More Information Alan S. Halperin I Partner Paul, Weiss, Rifkind. Wharton 8 Garrison LLP 1285 Avenue of the Americas I New York. NY 10019-6064 3 (Direct Phone (2,2, 132 313 (Direct Rug 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. EFTA00979163 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 EFTA00979164