From: Fenn, Patrick <
Sent: Tuesday, May 21, 2013 4:00 AM
To: jeevacation@gmail.com*
Subject: Re: FW: Early Termination Calculation
Would likely mean liquidating AP Prof and BRH. Theoretically could do so without triggering Tufts gain. Might be some
non-tax hoops to jump through but presumably could be mastered. Would need to consider additional implications and
discuss with Paul Weiss (company counsel). Not sure about holding in "different pockets". AMH is one many entities that
comprise the AOGs. Exchanges for Class A Shares only work if exchange an AOG Unit. Something to consider.
From: Jeffrey Epstein [mailto:jeevacation@gmail.comj
Sent: Monday, May 20, 2013 09:21 AM
To: Fenn, Patrick
Subject: Re: FW: Early Termination Calculation
can we distribute out amh? I want to end up owning the holder and the debt. in different pockets.
On Mon, May 20, 2013 at 9:08 AM, Fenn, Patrick > wrote:
Ok. Yes, thinking through possibilities.
From: Jeffrey Epstein (mailto:jeevacation@gmail.com <mailto:jeevacation@gmail.com> J
Sent: Monday, May 20, 2013 08:19 AM
To: Fenn, Patrick
Subject: Re: FW: Early Termination Calculation
could they run the calcuations at a 30 and 35 dollar price for apo , thanks, also have you given tought to
refreshing the basis in amh.? new loan,? partnership, guaranteed either payments or assignment of tra in whole?
On Mon, May 20, 2013 at 7:46 AM, Fenn, Patrick < >>
wrote:
EFTA_R1_00066334
EFTA01761528
Jeffrey,
Calculation from Brian Knudson at E&Y. Note that this relates only to the unexchanged units, and does
not include the existing TRA payments.
Regards
Hi Patrick,
Attached is the calculation that we put together for Leon. As we discussed, this only calculates the
estimated early termination payment with respect to the APP units held by Leon - it does not yet calculate the estimated
early termination payment with respect to remaining TRA benefits related to the 2007 exchange. I have added an
assumptions tab to the workbook outlining many of the items that we discussed. Thanks,
Brian
Brian Knudson I Partner I National Tax - Partnership and Joint Ventures
Ernst & Young LLP
20O South Sixth Street, Suite 1400, Minneapolis, Minnesota 55402, United States of America
Offic I Mobile:
<tel:%2B1%20612%20849%200339> I
Website: www.ey.com <http://www.ey.com>
Assistant: Lenora Wold I Phone:
<mailto
Thank you for considering the environmental impact of printing emails.
Any U.S. tax advice contained in the body of this e-mail was not intended or written to be used, and
cannot be used, by the recipient for the purpose of avoiding penalties that may be imposed under the Internal Revenue
Code or applicable state or local tax law provisions.
2
EFTA_R1_00066335
EFTA01761529
The information contained in this message may be privileged and confidential and protected from
disclosure. If the reader of this message is not the intended recipient, or an employee or agent responsible for delivering
this message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this
communication is strictly prohibited. If you have received this communication in error, please notify us immediately by
replying to the message and deleting it from your computer.
Notice required by law: This e-mail may constitute an advertisement or solicitation under U.S. law, if its
primary purpose is to advertise or promote a commercial product or service. You may choose not to receive advertising
and promotional messages from Ernst & Young LIP (except for Ernst & Young Online and the ey.com <http://ey.com>
website, which track e-mail preferences through a separate process) at this e-mail address by forwarding this message
to no-more-mail@ey.com <mailto:no-more-mail@ey.com> . If you do so, the sender of this message will be notified
promptly. Our principal postal address is 5 Times Square, New York, NY 10036. Thank you. Ernst & Young RP
IRS Circular 230 Notice Requirement: This communication is not given in the form of a covered opinion,
within the meaning of Circular 230 issued by the United States Secretary of the Treasury. Thus, we are required to
inform you that you cannot rely upon any tax advice contained in this communication for the purpose of avoiding United
States federal tax penalties. In addition, any tax advice contained in this communication may not be used to promote,
market or recommend a transaction to another party.
The information contained in this e-mail message is intended only for the personal and confidential use
of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e-
mail, and delete the original message.
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 jeevacation@gmail.com <mailto:jeevacation@gmail.com> , and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
IRS Circular 230 Notice Requirement: This communication is not given in the form of a covered opinion, within
the meaning of Circular 230 issued by the United States Secretary of the Treasury. Thus, we are required to inform you
that you cannot rely upon any tax advice contained in this communication for the purpose of avoiding United States
federal tax penalties. In addition, any tax advice contained in this communication may not be used to promote, market
or recommend a transaction to another party.
3
EFTA_R1_00066336
EFTA01761530
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-mail, and
delete the original message.
**************•***** ********r ****** ** ******** ** ******* *****
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
jeevacation@gmail.com <mailto:jeevacation@gmail.com> , and destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
IRS Circular 230 Notice Requirement: This communication is not given in the form of a covered opinion, within the
meaning of Circular 230 issued by the United States Secretary of the Treasury. Thus, we are required to inform you that
you cannot rely upon any tax advice contained in this communication for the purpose of avoiding United States federal
tax penalties. In addition, any tax advice contained in this communication may not be used to promote, market or
recommend a transaction to another party.
The information contained in this e-mail message is intended only for the personal and confidential use of the
recipient(s) named above. If you have received this communication in error, please notify us immediately by e-mail, and
delete the original message.
4
EFTA_R1_00066337
EFTA01761531