EFTA02006909.pdf

To: jeevacation©gmail.com 'eevacation mail.com • Jeffrey Epsteinbeevacation©gmail.corn] Cc: Eileen Alexanderso From: Ada Clapp Sent Thur 4/18/2013 4:10:26 PM Subject Re: Question re Restructuring Ok. Let me know what you conclude. I think the redemption solves the issue of whether or not to file a gift tax return to report the substitution (which I think Alan is inclined to want to do). Y Ada Clapp Black Family Partners cro Apollo Management 9 W 57th Street 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. On Apr 18, 2013, at 12:01 PM, Jeffrey Epstein <jeevacationOgmail.com> wrote: my initial recation is that i would like to use the substitution provison of teh 2006 trust, it is cleaner but let me think about it, the issues of complex valuations, deemeds gifts , and ap iv , give me pause. On Thu, Apr 18, 2013 at 11:43 AM, Ada Clapp wrote: Hi Jeffrey, EFTA_R1_00506501 EFTA02006909  I was wondering out loud with Eileen yesterday: instead of having Leon borrow funds to substitute into the 2006 Trust in exchange for BFP interests, have you considered having BFP borrow funds to be used to redeem the interests of all partners except Leon? I see the problem as the size of the loan but perhaps we could consider this as one piece of the solution. What do you think? Ada Clapp Black Family Partners cto Apollo Management 9 W 57th Street 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. 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 EFTA_R1_00506502 EFTA02006910 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 jeevacationegmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA_R1_00506503 EFTA02006911