EFTA01758259.pdf

From: Fenn, Patrick Sent: Sunday, May 19, 2013 4:56 PM To: [email protected]* Subject: Re: The TRA payments made now are treated as additional purchase price for the 2007 purchased partnership interests that in turn produce more amortization and imputed interest expense. Capital loss on early termination of TRA for unexchanged units might give rise to a deferred tax asset for accounting purposes, but then probably only if there was some expectation that it could be utilized. From: Jeffrey Epstein (mailto:[email protected] Sent: Sunday, May 19, 2013 12:52 PM To: Fenn, Patrick Subject: Re: how do they currently report the payments, as you are rightly concerned about a 750 capital loss On Sun, May 19, 2013 at 12:22 PM, Fenn, Patrick mailto > wrote: You mean for financial accounting purposes? From: Jeffrey Epstein (mailto:[email protected] <mailto:[email protected]> Sent: Sunday, May 19, 2013 12:01 PM To: Fenn, Patrick Subject: if the co reports the transaction with the tra, how do they record the fact that they will pay less taxes for the next 15 years. in exchange The information contained in this communication is EFTA_R1_00061056 EFTA01758259  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] <mailto:[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 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] <mailto:[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 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. 2 EFTA_R1_00061057 EFTA01758260