EFTA01088441.pdf

Estate Planning Overview Presented 切： Leon D.and Debra R.Black Overview of Estate Plan September 23,2013 Nancy A.Kistner,CFP8) Stevon L.Forrester,CFPOD Managing Director Vice President Wealth Strategies Advisor Associate Weal Strategies Advisor U.S.Trust,Bank of America Private Wealth Management 114 West 47th Street New York,New York 10036 EFTA01088441 Leon D. and Debra R. Black Overview of Estate Plan Statement of Disclosure Investment products melt et steam bonds and mutual funds: Are Not FDIC Insured May Lose Value Are Not Bank Guaranteed IbIPORTANT: This brielsommary is for dismission poryarm orgy. t dots not containleg:MIAs. inergnient. or insurance 'deice and cannot bereliedupon Mr implementation and/or protection from pecaltim. The proses/cm of usta estate pluming documents will mvern the dire:Mon of your estate. Mumscomb nith lour independent attorney and Lax Memo for twat and Us IMPORTANT: These pries:nomate estimates only mid axe based on constantlylbaccucci assumptions. Your actual results may be better or .one. longterm financial polo:nom cannot he made with any certainw. and arc never guarantee! Mnys consult with your independent allooleY and On a hine for kW:land las advice. I RS Circular 330 Disclosure: Pursuant to IRS Regulations, see infonn yea that any tax adage contained in thu COMM.:WNW* (including any attachment:Orsnot Intend/doe meta' to be used. and canna hewed Many person or entity for the impose °C(i) avoiding lax Mated penalties imposedby any pownmental tax authoriD or agency. or (ii)promoting. marketingor recommendiug to another party any transactionor matter dimemel wino. We Mee you to moult with an independent tae advisor on 'WI Patti:Mar tasUrcomuancek Investment products and services may be amiable through a relationship managed by U.S.Trust. Rank *IA:Imre. levate Wealth Management. or througha Idatlnmhlp nth ?demi Lynch Pew. Fenner & Smith likeyrodoid Certain U.S. least associates are uglitited upresentathes wieh Merrill Lynch. Perm. Femme & RnIN Incorporated and may skit you with inernment prodmts aed service* mood/el through Meta Lynch. Pierre. Fennel. is Smith Illan&OlAlltd aralothet Subs/Ainin a Bank of Ametica Corpontion However, CS. Trust doe not manage invertmets held at Merril Math. Nene Fenner & Smith Incomoneted and mu must shwa your representative to take action on the advice sheik Individual transudes you direct MR result ln your overall portfolio Ming invested ma manner whichmay differ from this report. In addition. throe materials may dismiss enders elements or' an indieidualk overall financial mile fore:NM wither C.S.Thist nor Merril los& Mee Fenner it Smith Inromorated gem as anadvisor. Memel Lynch, Pierce, Fenner & Smith Incorporated iota registered broker-dealer, member FINRA and SLIT. and a nholly oventdiobeiwy of Bank of America Corporation. Merrill Lynch, Pierce. Fenner &Smith IncorpotOod does cat sent as alas or lac al bidets. Several products such as mutual funds. variabk annuities, and other alternative investments that may be mentioned as an investment alternative for you me only to be :Mid 'Men %MOOS or MCOmPolied by a entreat prospectus andjor °Smog memoranda- The prospectus and/or dieting memoranda provide more complete Information on the product. Indudingthargm caroms and *pedal Investment risks. and should be read carefully before inverting The followingreport is for fiduciary use only. The amoebae presenting the report to mu is acting ethic: his or her fiduciary capacity with US.Dust, not vnthm his or her brewed capacity. If any. isitlx Merrill Lynch, Nerve. Fenner & Smith Inosrtiosied The information and data in the following report were retained from serves rhymed nibble Their amenity and ompletenters are not guaranteed. and the 'Ming of the same is not deemedan offer or minimax' for the purthase OF sate of smuntics. This report attempt* to meows a particular imbrue of Investments by avetapng the pc:don:weeof all anoraks m the Index. The index may belt Ifferlil tool. but am no way representative Mrpast pieformanm of a potindar fend or sootily, and is not representative of arofuture performance o(any particular imetment Assomptions is:staining inflation or lax ratesare atutrathe porpescs only and are not intended to perdict economic rerfonnance. Aro asset or portfolio ratninat arallor MornsPura or mud in this report arena intended to Sinful nor guarantee the 4MA MullsMan investment produce. IM&SIOM may not lotto directlyusan Index. This report is a preliminary analysis and not neeessatily the tactkal Will:unto( twommendgloco. This material is for Illustrative and educational purposes and has been prepared solely to assist in the mien of your inweament alternatives Youmould tomtit toonsoMelepl and/or las adviMer and thenviola", your representative I., tat tootostitte nest papa. This report does not constitute legal, tervording or topes witnessadvice. If you chose to follow an investment strategy set forth in the Slowing anon(s) istiusitissinn ofYour Pictrelts may 'welt in tar consequences. Again. thecontents of this priscoution should cat be acted upon ulthout consulting tonsorial° legal and/or tat achisors. All tax calculations herein are merely estimates and should not be tried upon for &Wed tax plannirg rumour. All Income laws we bided on flat tax ratesanddonee take all the details a(a states to us laws into account. This analysts h based on the calendar sesr.. All autos and hablhoes sue vsksd at theend of each year. Maths are also assumed to occur at the end deeds your. For the ant your of theanalystsonly. annual returns are ll0M-Jkd on a day basis U.S.'lluss. hank of Amerka Private Wealth Management operates through Bank of AMOS. and other subsidiarks of Rank of Anierica Commuting Bank of Anglia.. M. Member FDIC. ants Rank dAmenca Corporation. All rights recessed. Page 2 of 15 EFTA01088442 Leon D. and Debra FL Black Overview of Estate Plan Inventory of Family Assets as of August 16,2013 Liquid Assets - Investment Accounts U.S. Trust Cash Account $ 1.819.554 JPM Cash/Marketable Securities 6.549.618 Investments Works of Art-held through Art Entities $ 1.720.975.389 Collectibles (bronzes. rare books) 360.728.062 Black Family Partners LP (80% interest) 1.813.688.290 Various Investment Partnerships 2.720.424 AP Alternative Assets 13.854.962 AP Investment Europe 24.684 Avionetta LLC (Leon's 50.1%) 12.525.000 BJAV Marine Ltd. (Stadi-e-yacht) 25.000.000 Other-AIF IV Management Inc (split dollar nghts) 23.167.731 Real Estate- Personal Real Estate 103.000.000 Tangible Personal Property Household Personal Property $ 39.076.759 Automobiles 419.428 Total Personal Assets 5 4.123.549.901 Personal Liabilities Loan payable-Bank of America (secured by works of Alf) (440.000.000) Loan payable-Bank of America (Avioneta Hldgs 50.1%) (11.635.725) Loan payable (Heritage Trust) (1.638.667.370) Note Payable to Black Family Partners (219.003.003) Total Personal Liabilities 2.309.303.095 Total Estate Assets S 1.814.246.8061 Non-Includible Trust Assets 1992 Life Insurance Trust (death benefit) 20.003.003 1999 Life Insurance Trusts (death benefit) 150.000.003 Heritage Trust 2.509.537.000 Black 2011 Family Trusts (LDB 2011 LLC) 284.800.000 Mallory Trust 4.000.000 Total Trust Assets 2.968.337.000 Total Family Assets IS 4.782.583.806 Page 3 of 15 EFTA01088443 Leon D. and Debra R. Black Overview of Estate Plan Assumptions Exemption Amounts: Leon Debra Prior Taxable Gifts $ 5.120.000 $ 5.000.000 Available Unified Credit Amount $ 130.000 $ 250.000 Prior GST Exemption Allocation $ 3.500.000 $ 4.000.000 Available GST Exemption Amount $ 1.750.000 $ 1.250.000 Federal Estate Tax Federal Estate Tax Highest Federal Estate Highest New York Estate Year Exclusion & GST Credit Tax Rate Tax Rate Exemption Amounts 2013 5,250.000 $ 2.045,800 40% 16% Notes and Assumptions: • Leon and Debra are presumed to die in 2013 with Leon immediately predeceasing Debra. • Debra has transferred title to all residences to Leon as sole owner. • The Overview illustrates the decanting of the Black 2006 Family Trust and the Black Family 1997 Trust to the Heritage Trust. • Debra's Will and Revocable Trust provisions are presumed to mirror those in Leon's documents. • Administration expenses are assumed to be $5 million in Leon's estate and are assumed to be 1% of Debra's gross estate. • Leon selected $200 million of art from his estate for each child's Legacy Trust and $100 million from the Heritage Trust for each child's Legacy Trust. • Valuation discounts totaling 30% are applied to the value of Black Family Partner. L.P. ('BFP") interests. • On Leon's death. BFP interests will be used to pay off the Notes to the Heritage Trust and to BFP: the yacht and art will be sold to repay the art loans. Art will be sold on Debra's death to pay estate tax. • The plane owned by Avionetta will be sold and the proceeds used to repay the loan from Bank of America. • The Overview does not reflect the split-dollar transaction. • The provisions of the Leon D. Black Insurance Trust #2 are assumed to be identical to the Leon D. Black Insurance Trust #1 dated September 13. 1999. • Judy Black was bom on September 27. 1948. • Jon Ressler is assumed to be age 60. • 100% charitable deduction is assumed for fractional interests in art pledged to museums. Page 4 of 15 EFTA01088444 Leon D. and Debra R. Black Overview of Estate Plan Estate Flow Chart Upon Leon's Death Executers: Debra Black, Bany Cohen and Richard Ressler Leon Black Charitable Pledges Gross Estate Probate Property 4.121549.90! Fractional Interest In Art S I4.0(10.033 (owned with museums) Gross Estate 4.123.549.901 Total 14.000.033 Last Will and Testament Gross Estate $ 4.123.549.901 Administration Expenses (5.000.000) Charitable Pledges (14.000.000) Total Personal Liabilities (2,309.303.095) Residuary Estate S 1.795.246.806 Tangibles Passes to Revocable Trust Outri • ht Be • uest to Debra Trustees: Debra Black. Barry Cohen Tangible Property 39.496 187 and Riduud Ressler L. B. Revocable Trust Agreement Manhattan Apartments Outri•ht to Debra Residuary Estate: 1.795246.806 Manhattan Apartments $ 21.000 03D Art Entitles 8, collectibles to Marital Trust (1.631.393,604) Bequests to Debra (60.4196,187) Total 21.000 03D Bequestannuity (Melanie a Judy) (10253,856) NY Estate Tax (2.603,922) Federal Estate Tax (6.749,237) Cash Bequest Balance of Revocable Trust Residue 83.750,000 Passes to Marital Trust Bequest to Melanie Spinella $ 3,000.000 1 Marital Trusts Total Cash Legacies 3,000.000 GST Exempt Marital Trust 1.750.000 Lifetime Annuity Non-Exempt Marital Trust: for Judy Black Art Entities & collectibles 1.631 393.604 Annuity 7.253.856 Residences 82 000.000 Balance of Revocable Trust Residue (01 Total Annuity S 7.253.856 Total Marital Trusts 1.715 143.604 Page 5 of 15 EFTA01088445 Leon D. and Debra R. Black Overview of Estate Plan Estate Flow Chart Upon Debra's Death MARR0( MeMal TRIM Wei Detre% ROM Barry Cohan and Richard Ressler Lifetime Annuity Debra Black Marital Trusts Debra Black for Jon Hessler (Under L. B. Revocable Trust) Gross Estate TotM Marital Trusts 1,715,143.004 Tangible Property 39.496.187 Annuity S 8.48A 302 Annuity Ice Jon Ressler (8.484,302) Manhattan Apartments 21.030.000 8.484.302 Bequest of Art to Heritage Trust $ (800.039000) GST Exempt Mantel Trust (1.750000) Net Proceeds sale of Avionetta (49.9%) 885.72$ Bequest of Debra's GST Exempt Amount (1250000) NY Estate Tax (269.486.028) Gross Estate 61 381912 Federal Estate Tax (567.153,6591 Marital Trust Residue 67.019.014 Passes to the Foundation Last Will and Testament Gross Estate S 61.381.912 Administration Expenses (2%) (1.227.638) Residuary Estate 00.154274 Passes to Revocable Trust Leon Black Family Foundation Heritage Trust Non.Exenipt Marital Trust Residue 67.019.614 Revocable Trust Agreement (including residences) GST Exempt Marital Trust Residue 1.750.000 of Debra Black Debra's Revocable Trust Residue 20.658.087 Debra's GST Exempt Amount Bequest 1.250.000 Total Added Upon Debra's Death: S 87.677.701 Bequest of Art to Legacy Trusts 800000000 Residuary Estate 60.154274 Total Added Upon Debra's Death: S 801000.000 Tangibles to Children (99.496.187).- , Revocable Trust Residue 20.658,087 Passes to Foundation =5!!!!!§a 4 Tangible Property 39 496 187 Page 6 of 15 EFTA01088446 Leon D. and Debra R. Black Overview of Estate Plan Estimated Estate Tax Calculations Leon's Gross Estate $ 4.123,549,901 Debra's Gross Estate S 1.776.525,516 Deductions: Less Deductions: Liabilities (2,309,303,095) Liabilities Administration Expenses (5,000,000) Administration Expenses (1,227,638) Charitable Deduction (14,000,000) Charitable Deduction (87,677,702) Marital Deduction (1,775,639,791) Marital Deduction Estimated New York Estate Tax (2,603,922) Estimated New York Estate Tax (269,486,028) Plus: Adjusted Taxable Gifts 5,120,000 Plus Adjusted Taxable Gifts 5,000,000 Taxable Estate $ 22,123,093 Taxable Estate $ 1,423,134,148 Tentative Federal Estate Tax 8,795,037 Tentative Federal Estate Tax 569,199,459 Less Credits/Payments: Less Credits/Payments: Unified Credit (2.045,800) Unified Credit (2.045.800) Gift Taxes Paid Gift Taxes Paid Estimated Federal Estate Tax S 6,749,237 Estimated Federal Estate Tax S 567,153,659 Estimated New York Estate Tax S 2,603,922 Estimated New York Estate Tax $ 269,486,028 Total Estate Tax Due Upon Leon's Death 9,353,159 Total Estate Tax Due Upon Debra's Death 836,639,6871 Combined Federal Estate S 573.902,896 Combined State Estate Tax 272.089.951 Total Combined Estate Tax Is 845,992,847 Page 7 of 15 EFTA01088447 Leon D. and Debra R. Black Overview of Estate Plan Debra's Assets Upon Leon's Death Assets Transferred/Conveyed to Debra Upon Leon's Death Debra Black Financial Inventory Upon Leon's Death Outright Trust Life Insurance Proceeds Avionetta Sale Proceeds 885,725 Manhattan Apartments 21,000,000 Manhattan Apartments & Residences 21,000,000 82,000,000 Residences 82,000,000 Tangible Personal Property 39,496,187 Tangible Personal Property 39,496,187 Artwork 1,631,393,604 Artwork 1,631,393,604 GST-Exempt Marital Trust 1,750,000 GST-Exempt Marital Trust 1,750.000 $ 60,496,187 S 1,715,143.604 $ 61,381,912 $ 1,715,143.604 Total $ 1,775,639,791 Total (1) $ 1,776,525,516 (1) Assets will be included in Debra's estate for Federal and New York estate tax purposes. Page 8 of 15 EFTA01088448 Leon D. and Debra R. Black Overview of Estate Plan Heritage Trust Flow Chart - Following Debra's Death Trustees:Bany Cohen. Richard Ressler. John Hannan. Benarrm Black Joshua Laadt.Atexander Bieck and Maass Mack Heritage Trust That Assets (Net of Liablities) 2.509.537.000 Added Upon Danes Death: GST Everitt Marital Trust Residue 1.750.000 DebraS GST Exempt Bequest 1.250.000 Bequest of Art to Legacy Trusts 800.000.000 Total 3.312.637.000 S •Pot" Trust A single Heritage Trust is created for Debra and Leon's descendants and for separate Legacy Trusts are created (one for each of Leon's chideen). The Trustees may thstitute Mame and principal to Debra and Lecti's descendants. sonnet to the dsobtrion gudeines ("Alined in the Trust Agreement. After Leon's death. an and collectbles held in the Heritage Trust designated fa a particular chid wit be distriomed to such chIchs Legacy Trust. Alter Debm's death sirrilady designated items in the Marital Trust will be dist:it:rod to a child's Legacy Trust. After Lea's death the Trustees shall distribute the folowing to each cites Legacy Trust. 1 510 miticm when the child attains age 30 (request it is used ID accoite a principal residence). 2 $50 mincer when the child attains age 35. 3 $100 rrillian when the child attains age 40. 4 After Debra's death. selected works of art will pass to each child's Legacy Trial. If a child dies alder age 40. the above amounts will be cis:Jed into shares for the child's descendants and each share wit be held in a separate Legacy Trust for each such descendant. 'Jr Trustees: Been Cohen. Rased Ressler and JohnHannan Separate Lega Trutt* Duping the benelstanfs We: 1 The Trustee may pay the incase and principal to the beneficiary subject to disbibution guidelines (the descendant's financial acumen. marital discord. creditor claims. pendng lidgption. or substance abuse). 2 Trustees are authorized to invest in a business venture proposed by the beneficiary. so Rag as it is a career commernent 3 After age 35. the beneficiary is a atheist of blather Legacy Trust. Al the beneficiary's death: A chid may by Wit appoint the remaining TRIM properly among Leon's descendants and up to 510 mitton in favor of a spouse. My property not appointed will be Onided ii equal shares for the Lem(oary's children. Legacy Trust Matt Benjamin Eli Black Legacy Trued Itoro Joshua Max Black Legacy Trust Ebro Alexander S. Black Legacy Trust Ship Vlobtia R. Black Adsorb 5 300.000.000 Artwork 300.000.000 Otoork 300.000.000 Artwork 300.000.000 Cash Distribution 5 160.000.000 Cash Distribution $ 160.0^A.000 Cash Distribution $ 160.000.000 Cash Distribution S 160.000.000 Page 9 of 15 EFTA01088449 Leon D. and Debra R. Black Overview of Estate Plan Black 2011 Family Trust Flow Chart - Following Debra's Death Trustees: Barry Cohen and John Hannan Black 2011 Family Trust Administrative Trustee: U.S. Trust Company of Delaware LOB 2011 Lit S 284.800.000 Property is held in four separate Tr sty, one for each child: 1 Prior to age 25. Trustees have discretion to pay the child income. 2 After age 25, child receives all trust income quarterly. 3 Trustees have broad discretion to distribute principal to the child. 4 Each child's trust terminates upon the child's death: - If Leon and Debra are deceased and child was over age 35, child may appoint the principal of hisMer trust to Leon's issue - Unappointed assets will pass to child's issue, subject to lifetime trusts. V 2011 Trust VW° Benjamin Eli Black 2011 Trust frbio J shua Max Black 2011 Trust fibto Alexander S. Black 2011 Trust fibre Victoria R. Black $ 71.200.000 S 71.200.000 S 71.200.000 S 71.200.000 Page 10 of 15 EFTA01088450 Leon D. and Debra R. Black Overview of Estate Plan Leon D. Black Insurance Trusts #1 & #2 Flow Chart - Following Debra's Death Trustees: Norman Brownstein, then 1999 Life Insurance Trusts John Hannan 91 & 92 Combined Death Benefit $ 150.000.000 1 Upon the death of the survivor of Leon and Debra. Trust principal is divided into separate trusts: one for each of Leon's children. 1 Prior to age 21. Trustee has discretion to pay the child income. 2 After age 21. child receives all trust income quarterly. 3 The Trustee has broad discretion to pay principal to the child. 4 Each child's trust terminates 21 years after the death of the survivor of: - Leon. Debra and their issue living on 9/13/99. 5 Child has a testamentary power to appoint the trust to his/her issue. - Asset not appointed will pass to the child's issue. 1999 Trusts f/bio Benjamin Eli Black 1999 Trusts Mato Joshua Max Black 1999 Trusts f/b/o Alexander S. Black 1999 Trusts f/b/o Victoria R. Black $ 37.500.000 37.500.000 S 37.500.000 $ 37.500.000 Page 11 of 15 EFTA01088451 Leon D. and Debra R. Black Overview of Estate Plan Debra and Leon D. Black Life Insurance Trust Flow Chart • Following Debra's Death Trustee: Barry Cohen 1992 Life Insurance Trust Death Benefit: 520.000.000 1. Upon the death of the survivor of Debra and Leon. Trust is &ewe tutu separate trusts: one for each of Leon's children. 1 Prior to age 25. Trustees has discretion to pay the child income. 2 After age 25. the child receives all trust income quarterly. 3 Trustee has broad discretion to pay principal to the child. 4 Trustee is authorized (if deemed advisable) to distribute principal: - 1/4th at age 30: - another 1/3rd at age 35: - another 1/2 at age 40: and - the balance of the child's trust principal at age 45. 5 If the child dies prior to age 45. assets will pass to the child's issue. subject to trust until age 45. 1992 Trust Indio Benjamin Eli Black 1992 Trust trtxfo Joshua Max Black 1992 Trust fiblo Alexander S. Black 1992 Trust Ohio Victoria R. Black S 5.000.000 $ 5.000.000 5.000.000 $ 5.000.000 Page 12 of 15 EFTA01088452 Leon D. and Debra R. Black Overview of Estate Plan Mallory Trust Flow Chart - Following Debra's Death Trustee: Richard Ressler Mallory That Assets 4.000.000 Upon the death of the survivor of Leon and Debra. any property not appointed by Leon at his death will be divided into per stirpttal shares for Debra's descendants. 1. Each share for a descendant of Debra will be held in a separate Trust for the lifetime of the beneficiary: - The Independent Trustee must distribute income and principal needed for the beneficiary's health, education, support and maintenance. - The Independent Trustees also has broad discretion to distribute income and principal to the beneficiary (or any purpose. - After age 35. the beneficiary may appoint income and principal Trustees: After age 35, a child can be among Debra's descendants. co-Trustee of his/her separate Trust. 2. At the beneficiary's death: - The beneficiary's Trust will terminate and will be distributed as the beneficiary appoints. Any property not appointed will be distributed to his/her descendants, subject to the same trust terms. Trust MA) Benjamin Eli Black Trust %to Joshua Max Black Trust f/b/o Alexander S. Black Trust bloro Victoria R. Black $ 1.000.000 S 1.000.000 $ 1.000.000 S 1,000.000 Page 13 of 15 EFTA01088453 Leon D. and Debra R. Black 2013 Estate Planning Overview Distributions to Children and the Black Family Foundation Upon Leon's (Debra's Death Family Disposlave Upon Leon's Upon Debra's Lifetime fl aming Provisions Dead) Dea0 Benjamin Ell Black $ 870,774,928 1992 Insurance Trust Trust until age 45 5 S - 5.000.000 1999 Insurance Trusts Trust for Life 37.500.000 Heritage Trust Trust for Life 750.000 285.450.882 Legacy Trust Trust for Life 200.000.000 260.000.000 Black 2011 Family Trust Trust for Life 71.200.000 Mallory Trust Trust for Life 1,000.000 Tangibles Outright from Debra's Estate OuirigN 9.870.047 Joshua Max Black $ 870,774,928 1992 Insurance Trust Trust until age 45 S $ - $ srroospoo 1999 Insurance Trusts Trust for Life - 37.500.000 Heritage Trust Trust for Life 750.000 285.450.882 Legacy Trust Trust for Life 200.000.000 260.000.000 Black 2011 Family Trust Trust for Life 71.200.000 Mallory Trust Trust for Lite 1.000.000 Tangibles Outright from Debra's Estate OutrigN 9.874.047 Alexander S. Black S 870.774.928 1992 Insurance Trust Trust until age 45 5 5 - $ Locrospoo 1999 Insurance Trusts Trust for Life - 37,500.000 Heritage Trust Trust for Life 750.000 285.450.882 Legacy Trust Trust for Life 200.000.000 260.000.000 Black 2011 Family Trust Trust for Life 71.200.000 Mallory Trust Trust for Life 1,000.000 Tangibles Outright from Debra's Estate Outright 9.874.047 Victoria R. Black S 870.774.928 1992 Insurance Trust Trust until age 45 5 S - 5 5.000.000 1999 Insurance Trusts Trust for Life 37.500.000 Heritage Trust Trust for Life 750.000 285.450.882 Legacy Trust Trust for Life 200.000.000 260.000.000 Black 2011 Family Trust Trust for Life 71.200.000 Mallory Trust Trust for Life 1,000.000 Tangibles Outright from Debra's Estate Outright 9.870.047 Leon Black Family Foundation S 87.677,701 Estimated Taxes and Expenses 3,489,257,054 Federal Estate Tax S 6.749237 $ 567.153.659 New York Estate Tax 2.603,922 269.486.028 Administration Expenses 5.000.000 1.227.638 Capital Gains Tax 327.733.474 Llablities 2.309.303.095 Heritage Trust reduced by 20% capital gains tax paid on Leon's death mth respect to the 51.638.667.370 Note from Leon assumed to have a zero tea. Page 14 of 15