To: jeevacation©gmail.com[jeevacation©gmail.com];
jeevacation©gmail.com[jeevacation©gmail.com]
From: Eileen Alexanderson
Sent Fri 4/12/2013 10:44:37 PM
Subject: Re: Phaidon
Rate is 12%. No actual interest is paid though. Will send you the dots tomorrow morn and will relay how
Tom is handling.
From: Jeffrey Epstein [mailto:jeevacation@gmail.com]
Sent: Friday, April 12, 2013 06:39 PM Eastern Standard Time
To: Eileen Alexanderson
Subject: Re: Phaidon
sub-part f is not a problem at all, i would like to see how tom showed this investment, what is
the interest rate and terms of top mid debt. . i would like to see the debt dots
On Fri, Apr 12, 2013 at 6:06 PM, Eileen Alexanderso
wrote:
Jeffrey, See Phaidon org structure attached.
Mechanics of the purchase were as follows:
PLB LLC was funded with $54mil from the Black Family 1997 Trust, $3mil from the Black
Family 1997 GST Exempt Trust, and $10mil from the LDB 2011 LLC. JMWT LLC was
funded with $67,000 from Leon. These provided funding for the JMWT Acquisition LLP.
Bidco (JMWT Ltd) purchased the shares of Phaidon Press Ltd. The acquisition purchase price
paid from JMWT Ltd (through client account at Macfarlancs) was £41,000,000 + .005 stamp
tax ($67mi1).
In between, 2/3 of the funds were booked into the Topco as equity and 1/3 into the Midco as
debt. From a US perspective the funds into JMWT Ltd were treated as an equity contribution.
This debt is just between the topco and the midco and was established for UK interest
deductibility purposes and be converted to equity if we choose. Great care was taken to avoid
creating phantom income.
Profit or loss at Phaidon Press level has no impact for us until we choose to issue a dividend.
The one issue I believe you will need to consider if Phaidon was to purchase are relates to the
US tax aspects of subpart F income and whether Phaidon owning art (or eventually selling it at
a gain) would create that type of income. I believe it might.
As I mentioned this morn, I have a call on Monday morning set with the tax guy at PWC-you are
welcome to join-he is flexible re what time.
Best, E.
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