To: Jeffrey Epsteinfieeyacation©gmail.com]
From: Ada Clapp
Sent: Mon 4/1/2013 2:35:02 PM
Subject: Re:
Good. One other point when discussing decanting the 97 trust is that we should wait until after
the 2009 GRAT terminates in August to decant the 97 Trust as the 2009 GRAT remainder pours
into the 97 Trust.
Ada Clapp
Black Family Partners
No Apollo Management
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On Apr I, 2013, at 10:04 AM, Jeffrey Epstein <jeevacationagmail.com> wrote:
great, exactly, alan also agrees
On Mon, Apr 1, 2013 at 10:02 AM, Ada Clap wrote:
Hi Jeffrey,
Some of what you ask below was detailed in the estate flow chart U.S. Trust
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prepared a few months ago. That chart needs to be revised in light of additional
planning/information. I will ask UST to do that but first I want to take a look at
the underlying fund documents to confinn/ascenain what exactly happens with
each of the interests upon Leon's death (i.c., arc they fully vested on Leon's death,
monetized, etc.). Once I understand what happens to those interests, I can try to
figure out the tax implications to the various trusts/ Leon's estate.
Best,
Ada Clapp
Stack ramify Partners
IRS Circular 230 Disclosure:
Pursuant to IRS regulations, I inform you that any tax advice contained in this
communication (including attachments) is not intended or written to be
used, and cannot be used by any person or entity for the purpose of (i)
avoiding tax related penalties imposed by any governmental tax
authority, or (ii) promoting, marketing or recommending to another party
any transaction or matter discussed herein. I advise you to consult with
an independent tax advisor on your particular tax circumstances.
This communication, and any attachment, is for the intended recipient(s) only
and may contain information that is privileged, confidential and/or
proprietary If you are not the intended recipient, you are hereby notified
that further dissemination of this communication and its attachments is
prohibited. Please delete all copies of this communication and its
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On Mar 31, 2013, at 5:26 AM, Jefiley Epstein <jecvacation(iigmail.com> wrote:
ada as the priority, please detail ownership of the 94million units of
apollo. is brh. bfp. and the tax allocation in the partnership. entity
by entity and how the shares would be deistribuited to the children.
EFTA_R1_00320372
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EFTA_R1_00320373
EFTA01896009