EFTA02378156.pdf

From: Barry J. Cohen < M Sent: Friday, September 29, 2017 9:44 PM To: jeffrey E. Subject: Fractional ownership I am just getting to some of the emails you sent now that we closed the G650 purchase. There were 3 mechanical failures discovered when we went to fly the plane back from inspection. Delayed the closing over 24 hours. That's after Gulfstream inspected it for 2 weeks and told us everything was fine. Thank you very much for your help on the plane transactions. You were extremely helpful. On fractional shares, is your point that whacking up plane ownership among various family-related entities is not an audit risk? I understood the point you were making about fractional ownership helping to preserve at least some deductions if there is a problem in one entity, at least you are preserving deductions in other entities. The aviation advisors at MWE and EY (whose names I have given you previously) thought that this kind of fractional ownership marginally contributed to audit risk, for the reasons stated. Among the points made were (1) they were very confident in our tax position in the structure they recommended and (2) the trend in audits is toward broad audits of all related entities. I can't say if they are right or wrong, but every one of them was dismissive of the idea. From: jeffrey E. [mailto:[email protected]] Sent: Friday, September 15, 2017 7:43 PM To: Barry J. Cohen Subject: [External] xhttp://www.metrocorpcounsel.com/articles/19450/aircraft-tax-audits-%E2%80%93-game-tomes chttp://www.metrocorpcounsel.com/articles/19450/aircraft-tax-audits-%E2%.3O%93-game-tomes> read the first paragraph, do you see anything about fractional shares. NO . you dont. 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, EFTA_R1_01389879 EFTA02378156 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] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 2 EFTA_R1_01389880 EFTA02378157