EFTA00838143Set 9
2015-12-245p1,784w
From: Richard Kahn
To: Jeffrey Epstein <jeevacation@gmail.com>
Subject: Fwd: Alert: FIRPTA and REIT Reform Provisions in the New Tax Law Open Door to Increased
Foreign Investment in U.S. Real Property ... Group
Date: December 23, 2015 at 3:02:13 PM EST
To:
Subject: Alert: FIRPTA and REIT Reform Provisions in the New Tax Law Open Door to Increased
Foreign Investment ... Reply-To:
TAX ALERT DECEMBER 23, 2015
For further information about this Alert, please
FIRPTA and REIT Reform contact:
Provisions in New Tax Law Steven Etkind
Partner
Open Door
https://www.justice.gov/epstein/files/DataSet%209/EFTA00838143.pdf
EFTA01104578Set 9
2013-01-019p6,988w
Withholding as required by the Foreign Investment in Real Property
69 Tax Act, (hereinafter "FIRPTA"), Seller additionally agrees that such Tax Withholding must be collected
70 from Seller by Buyer ... Agent at the time of Closing. In the event Seller is not subject to FIRPTA,
71 Seller shall be required as a condition of Closing to sign appropriate affidavits certifying ... that Seller is not
72 subject to FIRPTA. It is Seller's responsibility to seek independent tax advice or counselprior to the Closing
73 Date regarding such tar matters
https://www.justice.gov/epstein/files/DataSet%209/EFTA01104578.pdf
EFTA01079628Set 9
16p11,265w
EIIIINO VALUATION,
CCIITAOT
THE COUNTY PROPERTY APPROISP.RS OFFICE FOR II(FORMATION.
in CO FIRPTA TAX WITINOLI/INQI Seat otalt ban 0 got 11000 l fitly It 'Rao person" to dented ... Waimea In Rani ',Nona?, Tar Act (•FIRPTA'). arm ao some shoe convoy rob Hippo,
en eater may «qua ato.Nn tdakmai eon el aodno. E OoTer Is nal a Ilcoolgn porton ... FOREIGN INVESTMENT IN REAL PROPERTY TAX
Ste "foreign parson" as delinod by FIRPTA, Soction 1445 of ACT (`FIRP7 A"); u u seller of LES. mat property is
ur property
https://www.justice.gov/epstein/files/DataSet%209/EFTA01079628.pdf
EFTA01078478Set 9
2014-06-1731p13,124w
foreign person, which certificate shall be in
the forni then required by FIRPTA, or a withholding certificate from the I.R.S. If Seller fails to deliver the aforesaid certificate ... urchaser is not entitled under FIRPTA to rely on such certificate, Purchaser shall deduct and withhold from the purchase prig a
sum equal to 10% thereof(or any lesser amount
https://www.justice.gov/epstein/files/DataSet%209/EFTA01078478.pdf
EFTA00312994Set 9
1999-12-3121p5,333w
foreign person,
which certification shall be in the form then required by "FIRPTA" (as hereinafter defined);
provided, however, that, in the event that the Seller fails to deliver the same ... Revenue Code of 1986, as amended (the "Code"), and the regulations promulgated thereunder
(collectively, "FIRPTA").
5.1.14. Exhibit B hereto is a true, complete and correct copy of
the Nominee Agreement
https://www.justice.gov/epstein/files/DataSet%209/EFTA00312994.pdf
EFTA00595846Set 9
2016-05-1076p47,451w
USRPI in the hands of the
qualified shareholder and will be subject to FIRPTA.
Qualified Foreign Pension Funds. A "qualified foreign pension fund" is any trust, corporation, or other
organization ... such income is taxed at a reduced rate.
Effective February 16, 2016, the FIRPTA withholding tax rate will increase to 15% from 10% with respect
to a purchase
https://www.justice.gov/epstein/files/DataSet%209/EFTA00595846.pdf