EFTA00986062.pdf

From: Richard Joslin < To: Jeffrey Epstein <[email protected]> Subject: Fwd: Premium Payments for Trust #2 Date: Sat, 22 Mar 2014 21:49:23 +0000 Fyi. I am around if you are available. Begin forwarded message: From: Ada Clapp < Date: March 21, 2014 at 6:38:54 PM EDT To: Eileen Alexanderson Cc: Richard Joslin Subject: Premium Payments for Trust #2 Hi Eileen, I wanted to "memorialize" my discussion with Roger Cammon regarding the premium payment amounts and due dates for the second-to-die polices held in Trust #2. Roger noted the following: With Variable life insurance, the true mortality costs of the insurance (plus administrative expenses) are deducted monthly from the funds held in policies (the current policy investments or "cash surrender values"). They are not paid from the premium payments. So for those years that AIF IV did not pay premiums under the split-dollar agreements, no portion of the cash value was used to pay the scheduled premium amount (that's good news). Roger noted that premiums are not really due on the register dates of the policies. The scheduled premium amounts are also flexible. Basically, the Trustees can choose to never pay a premium or to pay whatever they want whenever they want. Failing to pay the scheduled premiums may affect the amount of the death benefit as the investment portfolio may be inadequate to pay mortality charges and some policies may lapse (See Option 1 of Roger's illustrations "No Further Premium Outlay"). This, of course, depends entirely on performance of the investment portfolio. Roger's advice was not to pay a premium now but to wait until we have terminated the split dollar agreement for Trust #2 and the Trustees have decided how we wish to move forward with the policies (considering his Option 1 and Option 2 proposals). Ada Clapp Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022 Direct Dial: 646-589-0303 Fax: 646-589-0330 Email: IRS Circular 230 Disclosure: Pursuant to IRS regulations, I inform you that any tax advice contained in this communication (including attachments) is not intended or written to be used, and cannot be used, by any person or EFTA00986062 entity for the purposes of (i) avoiding tax related penalties imposed by any governmental tax authority, or (ii) proposing, marketing or recommending to another party any transaction or matter discussed herein. I advise you to consult with an independent tax advisor on your particular tax circumstances. This communication and any attachment is for the intended recipient(s) only and may contain information that is privileged, confidential and/or proprietary. If you are not the intended recipient, you are hereby notified that further dissemination of this communication and its attachments is prohibited. Please delete all copies of this communication and its attachments and notify me immediately that you have received them in error. Thank you. EFTA00986063