EFTA00828311.pdf

From: "Jeffrey E." <[email protected]> To: Melanie Spinella Subject: Fwd: Date: Mon, 02 May 2016 15:59:37 +0000 brads going to present me his ideas on presentation. ? . re tra fire drill review. needs a goal.. not merely see what categories things fall into . amendments should be tailored for benefit. not just clarified. Forwarded message From: Brad Wechsler <I Date: Mon, May 2, 2016 at 11:53 AM Subject: Re: To: "eevacation mail.com" <*eevacation mail.com> Cc: ' ' Jeffrey-let me give you the top-line and others can fill in as necessary on the issues noted below and progress. 1. BRH k: key point is that both apo and pw have indicated that their read is that no two principals can take an action that is prejudicial to the thirds estate. This is key but must be socialized with mart and josh (by johns) and then be clearly reflected. A. Of lesser importance, wendy is trying to push thru the 754 election at ap professionals, make certain an estate has access to "information rights", see if the three partners want mfn investment rights to continue past death and fix some language "clarifications. Wendy is quarterbacking this and timing is apo dependent which means likely to be a process. On some none "fire-drill" issues which are nonetheless quite impt, pls note: 2. People are comfortable with TRA transfer with respect to 2007 stock sales and, I believe, are expressing "sufficient comfort" with respect to a TRA transfer for future sales. There are definitely imbedded issues with respect to "completed gifts" and creating a separation from BRH without causing tax effects. Nonetheless, it appears we'll come out ok. 3. TIC still appears somewhat problematic to alan or said differently: I don't believe AH is comfortable with "nominal ownership and exclusive use". 4. We (and you) now know that a clat works and we can have an ultimate beneficiary as the foundation, a clat or both. You, leon and alan have to decide whether you want to "hard wire" the clat into the planning today (can do one that has some built in flexibility) or defer to a later date. 5. By later today or tomorrow I shld be able to show you "my take" on how to simply present the grat back-up. Obviously feel free to reach out to any on and all for more detail on the above. B From: Jeffrey E. [mallto:[email protected] Sent: Monday, Ma 02 2016 06:20 AM To: Ma Clapp < >, Brad Wechsler Subject: where are we with re do of fire drill does EFTA00828311  please note 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 JEE 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 [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved IMAXS is a registered trademark of IMAX Corporation. IMPORTANT NOTICE Information contained in this e-mail correspondence and any attachments is confidential information intended only for the use of the individual or entity named above. Any reader of this message who is not the intended recipient of this correspondence is hereby notified that any dissemination. distribution. copying or communication of th ' correspondence is strictly prohibited. If this e-mail was not addressed to you . please immediately notify us by phone in Canada at collect calls will be accepted) or by email at and delete and destroy this correspondence inadvertently sent to you. Thank you please note 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 JEE 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 [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00828312