EFTA02605828.pdf

From: jeffrey E. <[email protected]> Sent: Monday, September 25, 2017 3:27 PM To: Melanie Spinella Subject: HE is reading articles and sending questions THIS IS NOT SCHOOL From: Joseph Vinciguerra imailto Sent: Monday, September 25, 2017 10:43 AM To: Wimer, Ruth Cc: Deyoe, David; Barry J. Cohen; John Castrucci Subject: FET Question Hi Ruth, We had previously discussed how Part 91operations were not subject to FET. Take a look at the attached article, specifically the highlighte= section on page 4. In reading the CCA the article refers to (also attached), it seems like the IRS is taking the position that management agreements under Part 91 operations are subject to FET. Being that the CCA is from 2012, I would think=20 there has been some time to sort through the IRS' position. What are your thoughts on this and how it cou=d apply to our structure? Thanks. Joe Joseph M. Vinciguerra I Tax Director & Tax Counsel Elysium Management LLC I EFTA_R1_01796525 EFTA02605828  =AO please note The information contained in this communicati=n is confidential, may be attorney-client privileged, may constitute=inside information, and is intended only for the use of the addressee. =t is the property of JEE Unauthorized use, disclosure or copying of =his communication or any part thereof is strictly prohibited and may=be unlawful. If you have received this communication in error, please n=tify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and =estroy this communication and all copies thereof, including all attachm=nts. copyright -all rights reserved --94eb2c1924141859d8055a052f2b-- conversation-id 29949 date-last-viewed 0 date-received 1506353195 flags 8590195713 gmail-label-ids 7 remote-id 753162 2 EFTA_R1_01796526 EFTA02605829