defer payment of some or all of the taxes on the QEF's undistributed income subject to an interest charge on the
deferred amount. Prospective purchasers of Income Notes should ... Thus, absent an election to
defer payment of taxes, U.S. holders that make a QEF election may owe tax on significant "phantom" income.
The Issuer will provide, upon request ... information that a U.S. holder of Income Notes making a QEF
election is required to obtain for U.S. federal income tax purposes (e.g.. the U.S. holder's pro rata
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01365292.pdf
defer payment of some or all of the taxes on the QEF's undistributed income subject to an interest charge on the
deferred amount. Prospective purchasers of Income Notes should ... Thus, absent an election to
defer payment of taxes, U.S. holders that make a QEF election may owe tax on significant "phantom" income.
The Issuer will provide, upon request ... information that a U.S. holder of Income Notes making a QEF
election is required to obtain for U.S. federal income tax purposes (e.g.. the U.S. holder's pro rata
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01376111.pdf
character of such gains otherwise would be preserved
under the PFIC rules if a QEF election were made. Also. the PF1C rule permitting the deferral of tax on
undistributed earnings ... general terms, will vary depending on whether a U.S. holder has made a timely QEF election as described
above. If a timely QEF election has been made, dividends (which ... earnings and profits of the Issuer) allocable to amounts previously taxed pursuant to the QEF election
will not be taxable to U.S. holders. Similarly, if the Issuer
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01376112.pdf
character of such gains otherwise would be preserved under
the PFIC rules if a QEF election were made. Also, the PFIC rule permitting the deferral of tax on undistributed
earnings ... general terms, will vary depending on whether a U.S. holder has made a timely QEF election as described
above. See "— Investment in a Passive Foreign Investment Company." If a timely ... QEF election has been made,
dividends (which are distributions up to the amount of current and accumulated earnings and profits of the Issuer)
allocable to amounts previously taxed pursuant
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01365599.pdf
character of such gains otherwise would be preserved under
the PFIC rules if a QEF election were made. Also, the PFIC rule permitting the deferral of tax on undistributed
earnings ... general terms, will vary depending on whether a U.S. holder has made a timely QEF election as described
above. See "— Investment in a Passive Foreign Investment Company." If a timely ... QEF election has been made,
dividends (which are distributions up to the amount of current and accumulated earnings and profits of the Issuer)
allocable to amounts previously taxed pursuant
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01376323.pdf
unless a U.S. Holder elects to treat the Issuer as a "Qualified Electing Fund"
("QEF') (as described in the next paragraph), upon certain excess distributions (generally, a U.S. Holder ... Preferred Shareholder elects to treat the Issuer as a QEF, excess
distributions and gain will not be taxed as if recognized ratably over the U.S. Holder's holding period ... step up at death described above apply. Instead, a
U.S. Holder that makes a QEF election is required for each taxable year to include in income the U.S. Holder
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01386899.pdf
EFTA00714370Set 9
2015-10-131p183w
Richard Joslin
To: jeffrey E. <jeeyacation®grnail.corn>, "Dlugash, Alan" , John Castrucci <I
Subject: RE: QEF planning
Date: Tue, 13 Oct 2015 20:32:25 +0000
Attachments: QEF_DEFERRAL_PLANNING_V3.pdf
Latest update with ... jeffrey E.' <jeevacation@gmail.com>; 'Dlugash, Alan' <
Cc: Brad Wechsler John Castrucci <
Subject: RE: QEF planning
Attached is updated schedule. No NYS tax deferral available (only Federal income tax can be deferred ... jeffrey E.' <jeevacation@gmail.com>; 'Dlugash, Alan' .it >
Cc: Brad Wechsler John Castrucci
Subject: QEF planning
I attach a schedule that approximates the tax deferral for Federal and the savings
https://www.justice.gov/epstein/files/DataSet%209/EFTA00714370.pdf
EFTA00714431Set 9
2015-10-131p134w
Joslin
To: Jeffrey E. <jeeyacation@gmail.com>, "Dlugash, Alan" •
CC: Brad Wechsler < , John Castrucc
Subject: RE: QEF planning
Date: Tue, 13 Oct 2015 15:20:17 +0000
Attachments: QEF_DEFERRAL_PLANNING_V2.pdf
Attached is updated ... Jeffrey E.' <Je • • •' gash, Alan'
Cc: Brad Wechsle John Castrucci
Subject: QEF planning
I attach a schedule that approximates the tax deferral for Federal and the savings ... making an election to defer
tax on undistributed QEF earnings. I am awaiting to hear back from Deloitte and Apollo to confirm the amount of
undistributed QEF earnings
https://www.justice.gov/epstein/files/DataSet%209/EFTA00714431.pdf
EFTA00843675Set 9
2015-10-121p193w
From: "Jeffrey E." <jeevacation@gmail.com>
To: Melanie Spinella
Subject: Fwd: QEF planning
Date: Mon, 12 Oct 2015 23:25:20 +0000
Attachments: QEF_DEFERRAL_PLANNING.pdf
Forwarded message
From: Richard Joslin <
Date: Monday ... October 2015
Subject: QEF planning
To: "jeffrey E." <jeevacation®gmail.com>, "Dlugash, Alan"
Cc: Brad Wechsler , John Castrucci
I attach a schedule that approximates the tax deferral for Federal ... savings for NYS by making an election
to defer tax on undistributed QEF earnings. I am awaiting to hear back from Deloitte and Apollo to confirm the
amount of undistributed
https://www.justice.gov/epstein/files/DataSet%209/EFTA00843675.pdf
EFTA02391695Set 11
2014-08-152p281w
Sent: Friday, August 15, 2014 7:35 PM
To: jeffrey E.
Subject: Re: late QEF for BRH - pls check 2009
Understood. Last email on this ... Friday, August 15, 2014 1:25 PM
To: Abel Goce; 'Thomas Turrin'
Subject: late QEF for BRH - pls check 2009
Abel: pls review your files to find the comple ... copy from Apollo. Based on my initial=inspection, REM did not report the QEF
income in 2009 (initial year of ownership) from BRH. This makes all of the QEF posi
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02391695.pdf
Fund Secondary, such
U.S. Fund Secondary) makes a 'qualified electing fund" ("QEF") election with respect to a PFIC, the U.S. Investor would
in general be required to include in income ... deductible), but would avoid the interest charge and ordinary income treatment described above. A QEF
election may affect the timing, character and amount of income recognized by a U.S. Investor ... Fund of any distributable proceeds.
There can be no assurance that a QEF election will be available with respect to any PFIC in which the Fund directly or
indirectly invests
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01391172.pdf
Fund Secondary, such
U.S. Fund Secondary) makes a 'qualified electing fund" ("QEF") election with respect to a PFIC, the U.S. Investor would
in general be required to include in income ... deductible), but would avoid the interest charge and ordinary income treatment described above. A QEF
election may affect the timing, character and amount of income recognized by a U.S. Investor ... Fund of any distributable proceeds.
There can be no assurance that a QEF election will be available with respect to any PFIC in which the Fund directly or
indirectly invests
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01392474.pdf
Fund Secondary, such
U.S. Fund Secondary) makes a 'qualified electing fund" ("QEF") election with respect to a PFIC, the U.S. Investor would
in general be required to include in income ... deductible), but would avoid the interest charge and ordinary income treatment described above. A QEF
election may affect the timing, character and amount of income recognized by a U.S. Investor ... Fund of any distributable proceeds.
There can be no assurance that a QEF election will be available with respect to any PFIC in which the Fund directly or
indirectly invests
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01389831.pdf
EFTA00843672Set 9
2015-10-121p86w
jeffrey E. <jeevacation®gmail.com>, "Dlugash, Alan"
CC: Brad Wechsler a, John Castrucci cza>
Subject: QEF planning
Date: Mon, 12 Oct 2015 20:05:05 +0000
Attachments: QEF_DEFERRAL_PLANNING.pdf
I attach ... savings for NYS by making an election to defer
tax on undistributed QEF earnings. I am awaiting to hear back from Deloitte and Apollo to confirm the amount of
undistributed ... QEF earnings as of 12/31/2014 for the three PFIC's. I will keep you posted.
EFTA00843672
https://www.justice.gov/epstein/files/DataSet%209/EFTA00843672.pdf
EFTA00810285Set 9
21p6,756w
INFORMATION
IF APPLICABLE, VALAR GLOBAL FUND II LP HAS MADE TIMELY QUALIFIED
ELECTING FUND ("QEF") ELECTION(S) WITH RESPECT TO ITS INVESTMENTS IN
UNDERLYING PASSIVE FOREIGN INVESTMENT COMPANIES ("PFIC"), EFFECTIVE ... YEARS OF OWNERSHIP.
THE DIRECT US SHAREHOLDER THAT HAS MADE A QEF ELECTION FOR A PFIC IS
REQUIRED TO INCLUDE INCOME CURRENTLY UNDER IRC SECTION 1293, AND TO
FILE FORM ... PARTNER THAT HAS INVESTED IN A US PARTNERSHIP
THAT HAS MADE THE QEF ELECTION AND FILED FORM 8621 (IF APPLICABLE),
YOUR ALLOCABLE SHARE OF THIS INCOME IS NOT REQUIRED
https://www.justice.gov/epstein/files/DataSet%209/EFTA00810285.pdf