From: Jeffrey Epstein <jeevacationggmail.com>
To: Melanie Spinella
Subject: Fwd:
Date: Mon, 13 Jan 2014 12:12:04 +0000
Forwarded message
From: Alan S Halperin
Date: Mon, Jan 13, 2014 at 7:57 AM
Subject: Re:
To: Jeffrey Epstein <jeevacation(ipgmail.com>
In providing you with my previous answer, I had assumed that the decedent owned an interest in the
entity. My previous email therefore described how his ownership interest in the entity would be
reflected. The trusts ownership interest, in turn, would not be shown directly on any schedule on the
706. Rather, in response to questions in the 706, you attach riders describing various trusts associated
with the decedent. Generally, we do not disclose on the 706 the assets of trusts not subject to estate
tax. However, during the audit, the IRS often asks about the trust assets.
If the decedent owns the art directly, it is reflected on Schedule, with a supporting appraisal. The
artwork then will be sent to the Art Panel for valuation by the IRS.
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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. Rifkind. Wharton 8 Garrison LLP
(Dir ac
Americas I 19-6064
Dir t Phone) Direct Fax)
I ANvw.paulweiss.com
From: 'Jeffrey Epstein" < °vacation mail.com>
To: Man S Halperin
Dale: 01/13/2014 06:49 AM
Subject: Re:
and if owned personally
EFTA00871449
On Mon, Jan 13, 2014 at 7:45 AM, Alan S Halperin > wrote:
There would be one entry, in Schedule B (if a corporation) or F (if a partnership or LLC), with the name
of the entity and the value. In addition, there would be an appraisal which would describe the entity
(structure, history, ownership,purpose and assets) and the valuation.
IRS Circular 230 disclosure:
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, Rifkind. Wharton & Garrison LLP
1285 Avenue of the Americas I New York, NY 10019-6064
(Direct Phone) I (a. (Direct Fax)
I wv.w.paulweiss.com
From: 'Jeffrey Epstein" <eevacation mail.com>
To: Alan S Helped
Date: 01/13/2014 06:34 AM
Subject: Re:
what would the 706 look like , if it were in a partnership or even a c corp.
On Mon, Jan 13, 2014 at 7:29 AM, Alan S Halperin > wrote:
It helps, in my view, if rent is being paid.
IRS Circular 230 disclosure:
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.
Alan S. Halperin I Partner
Paul, Weiss, Rifkind, Wharton & Garrison LLP
1285 Avenue of the Americas I New York NY 10019-6064
(Direct Phone) Direct Fax)
From: "Jeffrey Epstein" [jeevacation@gmail.com]
Sent: 01/13/2014 07:23 AM AST
EFTA00871450
To: Alan Halperin
Subject: Re:
doesn;t a formal structure partnership . give us another layer of practical protection, valuing the art as a
partnership asset.. etc.
On Mon, Jan 13, 2014 at 5:30 AM, Alan S Halperin < wrote:
Well, if the goal is avoiding 2036, the best choices are (a) trust-owned art where Debra is a beneficiary (without
necessarily having any rent, but with a use agreement), or (b) trust-owned art with Leon paying rent.
IRS Circular 230 disclosure:
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.
Alan S. Halperin I Partner
Paul, Weiss, Rifkind, Wharton & Garrison LLP
the Americas I New York. NY 10019-6064
(Direct Phone) I (Direct Fax)
www.paulweiss.com
From: jeevacation
Sent: 01/12/2014 10:07 PM EST
To: Alan Halperin
Subject: Re:
Don't get lost. I care little about income imputation. The question is 2036!, and strengthening your comfort
level
Sony for all the typos .Sent from my iPhone
On Jan 12, 2014, at 9:53 PM, "Alan S Halperin" wrote:
As I reflect further, while the corporation cases are distinguishable from the partnership scenario, because the tax
regimes are different, I am concerned that rent-free use of partnership property could give rise to compensation
income (as opposed to dividend income). The idea of converting the partnership into an active art business entity
in fact lends itself to this result.
IRS Circular 230 disclosure:
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.
Alan S. Halperin I Partner
Paul, Weiss, Rifkind, Wharton & Garrison LLP
1285 Avenue of the Americas I New York, NY 10019-6064
EFTA00871451
Direct Phone) Direct Fax)
I www.paulweiss.com
From: "Jeffrey Epstein" Ueevacation®gmail.com
Sent: 01/12/2014 05:23 PM AST
To: Alan Halperin
I we formed an invesmtent partnership . to invest in art. and the trust and leon were partners. add his
collectibles. . and he arguably used partnership assets what is the risk. deemed distribution on non existnat
rent? seperate from 2036, maybe some alternative assets also added. ?
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destroy this communication and all copies thereof,
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attachments and notify us immediately.
The information contained in this communication is
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Jeffrey Epstein
Unauthorized use, disclosure or copying of this
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EFTA00871453
The information contained in this communication is
confidential, may be attorney-client privileged, may
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the use of the addressee. It is the property of
Jeffrey Epstein
Unauthorized use, disclosure or copying of this
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