From: "Fenn, Patrick"
To: 'Jeffrey Epstein' <jeevacation@gmail.com>
Subject: Your question and a question for you
Date: Fri, 11 Oct 2013 20:53:32 +0000
Hi Jeffrey. Has to do with potential implications under the anti-churning rules of section 197(f)(9) and the attribution
rules that are part of the regime. Basically denies a basis step up in property contributed to a partnership if a number of
requirements are met, including that the contributing party has or acquires a more than 20% interest in the transferee
partnership following the exchange. For this purpose, an individual partner is deemed to own what his or her partners
own, and family members are deemed to own what a family member owns. If Leon or his children were to acquire
(directly or indirectly) then the anti-churning rules could disallow the step up on an exchange for TRA purposes. I'll look
at attribution rules to see if there is a way to cut off the problem.
While I have you, the Company has been discussing again refinancing the existing AMH debt (and only refinancing the
debt). Any reason not to do that?
From: Jeffrey Epstein [malitoleevacation@gmail.00m]
Sent: Friday, October 11, 2013 3:18 PM
To: Fenn, Patrick
Subject:
john suydam tells me there are tax reasons why leon or his children cannot buy class a shares in the market
place. he says there are adverse tax consequences. ? facts?
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