EFTA02574906.pdf

From: Ada Clapp Sent: Friday, September 27, 2013 1:52 PM To: Jeffrey Epstein Cc: Melanie Spinella; Eileen Alexanderson; Alan S. Halperin Subject: Re: Pour-over and GRATs Good =orning Jeffrey, I understand that you want to move =uickly (though perhaps not all the nuances for your timing) but I am =ondering whether we have thoroughly considered the timing of the =our-over? Does it perhaps makes sense to do the pour-over =u>after you have received a favorable advisory opinion on the =ubstation for your client and we decide how to move forward with Leon's =ubstation. Two reasons to consider waiting for your client's =uling: 1. If we do the substation in the =006 Trust (which will disappear), what gets decanted into the =eritage Trust is the art. Nice and clean --no need to do a =ubstitution in the Heritage Trust that might draw attention if we =ecide to move forward on someone else's =uling. 2. The substitution language cited =n the petition for the ruling request is the Weil language contained in =he 2006 Trust. The Heritage Trust contains different substitution =anguage. We don't know how much the language will factor into the =dvisory Opinion. Might make it harder to rely on someone else's =pinion if we decide to move forward on that =asis. What do you =hink? New York NY 10019 phone: IRS Circular 230 =isclosure: Pursuant to IRS =egulations, I inform you that any tax advice contained in this =ommunication (including attachments) is not intended or written to be =sed, and cannot be used by any person or entity for the purpose of (i) =voiding tax related penalties imposed by any governmental tax =uthority, or (ii) promoting, marketing or recommending to another party =ny transaction or matter discussed herein. I advise you to consult with =n independent tax advisor on your particular tax =ircumstances. This communication, =nd any attachment, is for the intended recipient(s) only and may =ontain information that is privileged, confidential and/or proprietary =nbsp;lf you are not the intended recipient, you are hereby notified =hat further dissemination of this communication and its attachments is =rohibited. Please delete all copies of this communication and its =nbsp;attachments and notify me immediately that you have received them =n error. EFTA_R1_01746029 EFTA02574906 On Sep 27, 2013, at 9:11 AM, Jeffrey Epstein <[email protected]> =rote: lets =repare the new grats and pourover asap. =br> The =nformation contained in this communication is confidential, may be =ttorney-client privileged, may constitute inside information, and is intended only for the use of =he addressee. It is the property of Jeffrey Epstein Unauthorized =se, disclosure or copying of this communication or any part thereof =s strictly prohibited and may be unlawful. If you have received this communication in =rror, please notify us immediately by return e-mail or by e-mail to =a href="mailto:[email protected]" =arget="_blank">[email protected], and destroy this communication and all copies thereof, including all =ttachments. copyright -all rights reserved 2 EFTA_R1_01746030 EFTA02574907