EFTA02021884.pdf

Ada, I agree with you on making affirmative allocations of GST. We have always make affirmative allocations of gst with all relevant details. The gift tax returns will be on extension. I will send you the drafts of the returns when ready. Best, Tom THOMAS TURRIN, CPA Partner Raich Ende Matter & Co. LLP 1375 Broadway New York, New York 10018 l xi t 404) irect line) ax) ell) Email: Website: www.rem-co.com EFTA_R1_00527887 EFTA02021884 From: Ada Clapp [mailto Sent: Monday, April 08, 2013 6:19 PM To: Elyse G. Kirschner; Thomas Turrin Cc: Eileen Alexanderson; Jeffrey Epstein Subject: Black Family 2012 Gift Tax Reporting Obligations Hi Elyse and Tom, I wanted to follow up with you regarding the need to report the gifts each of Debra, Ben, Josh, Alex and Victoria made to new trusts they each created in 2012, as outlined in Elyse's attached memorandum. The memorandum implies that the family members will rely on the automatic allocation rules under the Treasury regulations for the allocation of GST exemption to their gifts. My preference is to make an affirmative allocation of GST exemption on the gift tax return reporting the gift, where that is the intention, rather than relying upon the automatic allocation rules. Not only is that the "safer" route, but it avoids confusion later as to how much GST exemption was used by an individual, as you have created a record for all involved to refer back to. If you elect to rely on the automatic allocation rules, would Elyse kindly confirm that the rules will apply to allocate GST exemption to 100% of each family member's 2012 gift (e.g., that they are indirect skips to "GST trusts" under the regs) . If instead, the gift tax returns will make affirmative allocations of each family member's GST exemption, I would like the opportunity to review the allocation language. Thanks in advance for your response. Best regards, Ada Clapp Black Family Partners Co Apollo Management 9 W 57th Street Now York NY 10019 phone: email: EFTA_R1_00527888 EFTA02021885 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 entity for the purpose of (i) avoiding tax related penalties imposed by any governmental tax authority, or (ii) promoting, 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. L - CONFIDENTIALITY STATEMENT: The information contained in this electronic communication, including any and all attachments and enclosures, may be privileged and is strictly confidential. intended solely for the use of the person(s) identified above to receive this communication. If you aro not the person(s) identified above to receive this communication, you aro hereby notified that you may not disclose print, copy. disseminate. or otherwise use the information contained herein. If you are an employee or agent of the person(s) identified above to EFTA_R1_00527889 EFTA02021886 receive this communication and, as such, you have been authorized to deliver this communication to such person(s), you may disclose, print. copy. disseminate. or otherwise use the information contained in this communication solely for the purpose of such delivery. Unauthorized interception an dfor use of this communication arefis strictly prohibited and may be punishable by law. If you have received this communication in error. please reply and notify the sender (only) of that fact and delete the communication. including any and all attachments and enclosures. from your computer or other electronic device on which you may have received this communication. CIRCULAR 230 DISCLOSURE: To insure compliance with requirements imposed by the Internal Revenue Service, we inform you that any tax advice contained in this communication (including any and all attachments). unless expressly stated otherwise. was not intended or written to be used and cannot be used for the purpose of (i) avoiding tax-related penalties imposed by the Internal Revenue Code or (ii) promoting, marketing, or recommending to another party any transaction(s) or tax•related matter(s) addressed herein. This communication may not be forwarded (other than to the addressee(s) identified above) without our express written consent. EFTA_R1_00527890 EFTA02021887