From: jeffrey E. <jeevacation@gmail.com>
Sent: Tuesday, December 8, 2015 5:19 PM
To: Halperin, Alan S
Subject: Re: Phaidon Transaction
267 b4 says truestee of grantor. . =the above ruling says two trustees ? are you=certain
wrote:
The attached ruling addresses Section 267(b)(5), which provides tha= if two trusts are established by the same
grantor, their fiduciaries are =elated to each other. The IRS ruled that, in making the fiduciaries related to each other,
the statute refers only t= their official actions as trustees of the common grantor's trusts= not to transactions involving
their personal assets or other trusts under=their administration. Accordingly, if an individual, in his individual capacity, is
buying an asset, 267 should =ot apply, even if that individual otherwise is a trustee of non-selling tr=st. Thus, Richard
need not resign as Trustee of the other trusts. Al=n
</=pan>
Alan=S. Halperin Part=er
Paul, Weiss, Rifkind, Wharton & Garrison LLP
1285 Avenue of the Americas I New York, NY 10019-6064
www.paulweiss.com
<http://www.paulweiss.com>
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EFTA_R1_01592830
EFTA02478339