EFTA02723531.pdf

To: [email protected][[email protected]]; Jeffrey [email protected]] From: Alan S Halperin Sent: Tue 9/10/2013 10:48:45 PM Subject: Re: Could you describe your plan, step by step, with a clear description of who is doing what, identifying the debt (obligor and obligee? Thanks. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. kdcral tax advice contained in this communication (including any attachments) is not intended or written to be used. and cannot be used, Ibr the purpose of(i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another parry any transaction or matter addressed herein. Alan S. Halperin I Partner Paul, Weiss, Ritkind, Wharton & Garrison LI.P From: "Jeffrey Epstein" ljeevacatim(dgmail.coml Sent: 09/09/2013 05:09 PM AST To: Alan I lalperin Subject: Re: no , not if in my example we have a billion of art and I billion of stock, and the stock doubles. he gets back all his stock and the art goes.. you are right about the sales tax on rent On Mon, Scp 9, 2013 at 5:03 PM, Alan S Halperin wrote: You "go" on vacation? Where have you been? ;) 1. The rent is subject to sales tax. 2. Leon will have to pay a $90 million per year in rent. 3. When GRAT expires, presto, Leon loses his income flow on the cashflow. I don't see how this is better than my very first proposal of a freeze partnership, where he gets the preferred return for life, I am happy to discuss. Alan IRS Circular 230 disclosure: EFTA_R1_02209802 EFTA02723531 To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. Click Here for More Information Alan S. Halperin I Partner Paul. Weiss. Rintind. Wharton & Garrison LLP 'am 'Jeffrey Epstein' <sevacationggmail °am> -o Alan S Halperin Date. 091W2013 041:47 PM Subjea lets asume we contribute 2 billion of art and the 400 million of debt to the prefeered partnership , the kids contribute 300 milliom of art and 300 of investments assets. ) enought to pay the coupon ). for a couple of hears. we then exchange the preferred interest for promissory note and rent art at afr plus 2,5. . no sales tax. . then we grat the current shares to gice the kids the upside. presto chango , i go on vacation. *********************************************************** 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 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 This message is intended only for the use of the Addressee and may contain information that is privileged and confidential. If you are not the intended EFTA_R1_02209603 EFTA02723532  recipient, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this communication in error, please erase all copies of the message and its attachments and notify us immediately. 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 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 This message is intended only for the use of the Addressee and may contain information that is privileged and confidential. If you are not the intended recipient, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this communication in error, please erase all copies of the message and its attachments and notify us immediately. EFTA_R1_02209604 EFTA02723533