EFTA02615307.pdf

From: jeffrey E. <[email protected]> Sent: Wednesday, September 20, 2017 9:05 PM To: Leon Black Subject: Fwd: EY audit experience I was told not ready surprised to see it was slready=passed for comments . Told you <=iv> Forwarded message From: Barry J. Cohen Date: Wed, =ep 20, 2017 at 4:42 PM Subject: Re: EY audit experience To: Jeffrey =. <[email protected] <mailto:[email protected]> &g=; CC: Melanie Spinella <[email protected] <mailto », Brad Wechsler =br> Yes. We have all of their comments. I hope to circulate shortly. =A0 Sent from my iPhone On Sep 20, 2017, at 3:54 PM, jeffrey E. <[email protected] <mailto:jeevacation@g=ail.com> wrote: very talented , question. has any of them tho=oughly reviewed the draft return , On Wed, Sep 20, 2017 at 3:38 PM, Barry J. Cohen =span> < <mailto >> wrote: Here is the summary we have on audit experience of o=r EY team. John Cook =93 Partner PCS • 2 or 3 High Wealth Audits • Significant number of Federal compliance audits (line by line)=u> • Federal audits on: • Passive versus active • At-Risk Limitations & basis • Schedule Cs • Charitable contri=ution and investment interest expense tracing Gift tax audits EFTA_R1_01814672 EFTA02615307  Significant number of NYS and CT — Statutory residency, dom=cile and income allocation audits </=pan> David Kirk =80 Partner— National Tax PCS * Spends 75-100 hours a year on audits * About 50% of the audits are Global High Wealth</=> * Most of the matters involve treatment o= pass-through items on the 1040s — passive loss, at- risk, interest=tracing and SE tax </=pan> Elda Di Re =80 Partner — National Tax PCS * S Global High Wealth Audits * 5 Gift Tax Audits * 6 =ederal compliance audits (audit of each line of return) =li class="m_3582487041588954438m_4691158948950989588MsoListParagraph" st=le="color:#1f497d">Dozens of regular 1040 audits </=pan> Greg Rosica =80 Partner Tax Significant experience=representing clients in Federal and state (NY, NJ, CT, GA, CA) audits incl=ding: - Complex financial tr=nsactions (distressed debt, related party transactions) involving individu=ls and their pass through entities - Audits of passive v =ctive status - Support for business=use of assets (real estate, airplanes, yachts, art, equestrian)<=u> - Investment v trade o= business classification (cap gain v ordinary, developer v investor) - Equity v debt treatm=nt in real estate transactions </=pan> Mitchell Kops =E2 Principal — National ITS Some audit experience =t Withers including: * Tax shelters, passive versus active * Private plane * Foreign Tax credit/deduction matter </=pan> Joseph Fuschetto=— Executive Director — PCS 2 EFTA_R1_01814673 EFTA02615308  • Many Federal compliance audits (line by line)<=> • Federal audits of Schedule Cs • Federal Audits of Schedule E — passive = active, at-risk • Multiple gift tax=audits • NYS residency and income al=ocation audits </=pan> Surya Shivakumar =E2 Senior Manager — PCS • Federal compliance audits (line by line) • NJ audits — full substantiation of all =ines and adjustments ` NYS residency=& income allocation audits chttps://m=ps.google.com/?q=445+Park+Avenue+Suite+1401 Vo0D+New+York,+NY+10022+%3=https://map s.google.com/?q%3D445%2BPark%2BAvenue%2BSuite%2B1401%250D%2BNew=2BYork,%2BNY%2B10022%26entry%3 Dgmail%26source%3Dg%3E&entry=gmail&=source=g> Barry J. Cohen =AOI Elysium Management,=11C I 445 Park Avenue Suite 1401 chttps://maps.google.comfig=445+Park+Ave=ue+Suite+1401%0D+New+York,+NY+10022&entry=gmail&source=g> New York, NY 10022 <https://maps.google.comfiq=445+Park+Ave=ue+Suite+1401%0D+New+York,+NY+10022&entry=gmail&source=g> = I Cell (917) ctel bcohen@elysll=.com <mailto:bcohen=elysllc.com> 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 3 EFTA_R1_01814674 EFTA02615309  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] <[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved =C2 please note The information contained in t=is communication is confidential, may be attorney-client privileged, ma= constitute inside information, and is intended only for the use of =he addressee. It is the property of JEE Unauthorized use, disclosure=or copying of this communication or any part thereof is strictly prohib=ted and may be unlawful. If you have received this communication in =rror, please notify us immediately by return e-mail or by e-mail to [email protected]=m, and destroy this communication and all copies thereof, includ=ng all attachments. copyright -all rights reserved --94eb2c05266eb9a2330559a555f7-- conversation-id 30789 date-last-viewed 0 date-received 1505941523 flags 8590195713 gmail-label-ids 7 remote-id 752032 4 EFTA_R1_01814675 EFTA02615310