From: jeffrey E. <jeevacation@gmail.com>
Sent: Tuesday, July 26, 2016 12:03 AM
To: Reid Hoffman
trust (CRT), where the stock can be sold on a tax-free basis.
In addition to avoiding gain recognition, a charitable income tax deduction is available b=sed on the full fair market value
of the contributed shares. Otherwise, the anticipatory assignment of income doctrine will be applied, so that the donor
will be to=ed on the transaction, despite donating the shares to charity. ..A0 To avoid this result, it is best to make the
donation of stock before shareholder approval of the inversion occurs.
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