To: Fenn, Patrick
From: Jeffrey Epstein
Sent Wed 5/15/2013 12:45:55 PM
Subject Re:
understood, but is the calculation every year that of an installment obligation or does it reflect the
specific character of the tax saved by apo? ie, the mix of tax savings or the mix of original sale
On Wed, May IS, 2013 at 8:40 AM, Fenn, Patrick < > wrote:
Gain on sale would be a combination of capital gain and ordinary income. The sale of the installment
obligation is considered to be an amount realized on the sale of the property giving rise to the
installment obligation. So a sale of the TRA would be taxed as part ordinary and part capital gain in
the same proportion as applies to the original sale of the partnership interest that gave rise to the
installment sale. Will get to Vincent today about the calculation.
From: Jeffrey Epstein [mailtoiteevacation(agmail.cOrn]
Sent: Wednesday, May 15, 2013 08:32 AM
To: Fenn, Patrick
Subject:
IF i understood you correctly, I assume the sale or exchange of the the remaining tra payments
would be considered disposition of installment debt so mostly keg. After vincent calculates
the amount, we should talk.
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