EFTA00385812.pdf

From: To: Darren Indyke Subject: Re: issues for conference call Date: Mon, 12 Aug 2013 16:41:42 +0000 great On Aug 12, 2013, at 12:31 PM, Darren Indyke wrote: FYI DARREN K. INDYKE DARREN K. INDYKE, PLLC 575 Lexington Avenue, 4th Floor New York, New York 10022 Telephone: (212) 971-1314 Telecopier: (646) 350-0378 Mobile: email: * * * it** * * ilk * * ********************* ** * * * * ******* irk ****** * *44 * * ************************ ***it The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren K. Indyke, PLLC. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail, and destroy this communication and all copies thereof, including all attachments. Copyright of Darren K. Indyke, PLLC - © 2011 Darren K. Indyke, PLLC —All rights reserved. * * * *** * * it * * it * * * ilk * * ilk * ** it* * * it* * * * te * * * * ******* irk ****** * *44 * * ***************************** Begin forwarded message: From: Gina Bryan <I Date: August 12, 2013 11:55:41 AM EDT To: Erika Kellerhals < "Dlu ash, Alan" Cc: "Darren K. Ind ke Richard Kahn >, "Guzman, Marylyn" < Subject: RE: issues for conference call Good Morning. Friday at 11:00am EST is fine. Please confirm. EFTA00385812 Thank you. Gina <image001.1pg> GrNA M. BRYAN OFFICE MANAGER 9100 PORT OF SALE MALL. STE 15 ST THOMAS, VI 00802-3602 Office: 340.779.2564 Fax: 888.316.9269 Notice: This communication may contain privileged or other confidential information. If you are not the intended recipient, or believe that you have received this communication in error, please do not print, copy, re-transmit, disseminate, or otherwise use this information. Also, please indicate to the sender that you have received this e-mail in error, and delete the copy you received. Thank you. Circular 230: To ensure compliance with the requirements imposed by the IRS, we inform you that any tax advice contained in our communication (including any attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding any tax penalty or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. From: Erika Kellerhals Sent: Monday, August 12, 2013 11:39 AM To: Dlugash, Alan Cc: Darren K. Indyke ( ); Richard Kahn; Guzman, Marylyn; Gina Bryan Subject: Re: issues for conference call I'll be unavailable for the next few hours so please coordinate with my assistant Gina at or by phone with what works for you. 340 779. 2564. Sent from my iPhone On Aug 12, 2013, at 11:32 AM, "Dlugash, Alan" Erika, > wrote: Unfortunately I am not available from 10AM — 4PM tomorrow (Tuesday), and I leave Wednesday at 1:45 PM for Panama where I'll be through Monday. l am OK with trying to call in from Panama Thursday or Friday at 11AM, but the calls are not always reliable. What is your preference? Alan Please note my new mailing address: Alan J. Dlugash EFTA00385813 Marks Paneth & Shron LLP 685 Third Avenue, New York, NY, 10017 P. 646 571 2424 F. 212-503-6359 C. E. <image001.gif> From: Erika Kellerhals [mailto: Sent: Monday, August 12, 2013 6:40 AM To: Dlugash, Alan Cc: Darren K. Indyke ( ); Richard Kahn Subject: Re: issues for conference call Alan, Thank you for your email. I am happy to address all of the issues you noted below — however — I now find myself in the situation where I learned last night that I have to fly to the states this morning. Is it possible for us to reschedule the call for either tomorrow at noon or Thursday between 9 and 12 or Friday between 9 and 1:30. I apologize for the last minute notice — but I only just learned that I would have to leave this am. Please advise. Erika A. Kellerhals Member <image002.jpg> Notice: This communication may contain privileged or other conridential information. II you are not the intended recipient, or believe that you have received this communication in error. please do not print. copy. re-transmit. disseminate. or otherwise use this information. Also. please indicate to the sender that you have received this e-mail in error. and delete the copy you received. Thank you. Circular 230: To ensure compliance with the requirements imposed by the IRS. we inform you that any tax advice contained in our communication (including any attachments) was not intended or written to be used, and cannot be used. for the purpose of (i) avoiding any tax penalty or (ii) promoting. marketing or recommending to another party any transaction or matter addressed herein. From: <Dlugash>, Alan Date: Monday, August 12, 2013 12:04 AM To: Erika Kellerhals < Cc: 'Darren Indyke' < Subject: issues for conference call Dear Erika, I am very much looking forward to our call Monday at noon. As I am still in the familiarization process with STC and the related personal tax issues, I am hoping to learn much from the call and anticipate that we can complement each other with issues going forward. To assist with the call, I have listed below some issues that I hope we can cover in an overview level to help me along with USVI issues. I will also be glad to provide you with assistance in any area that you think I can help with. 1) Conditions related to USVI benefits, including concepts of 90% tax exemption, separate interest and dividend tax exemption, nature of business required to be conducted, sourcing of income issues, requirement of clients outside USVI, etc. 2) Complications related to the mirror concept of taxation, including possible issues relating to: a) LLC's b) trusts, including grantor trusts c) concept of nominee EFTA00385814 d) meaning of "foreign" e) Private Foundation and Not-for Profit entities 3) USVI taxing authority guidance, assistance, letter rulings, etc. 4) US state taxation issues 5) C corporation issues I would also like to know of any issues and concepts of which you think I should be aware. Alan Alan J. Dlugash Marks Paneth & Shron LLP 685 Third Avenue, New York, NY, 10017 P. 646-571-2424 F. 212-503-6359 C. E. Marks, Paneth & Shron IRS CIRCULAR 230 DISCLOSURE: Treasury Regulations require us to inform you that any Federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. CONFIDENTIALITY NOTE: This transmission may contain confidential and/or privileged information. This information is intended for use by the individual or entity named above. If you are not the intended recipient, be aware that any disclosures, copying, distribution or use of the contents of this information is prohibited. If you have received this transmission in error, please notify this office immediately. IRS CIRCULAR 230 DISCLOSURE: Treasury Regulations require us to inform you that any Federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. CONFIDENTIALITY NOTE: This transmission may contain confidential and/or privileged information. This information is intended for use by the individual or EFTA00385815 entity named above. If you are not the intended recipient, be aware that any disclosures, copying, distribution or use of the contents of this information is prohibited. If you have received this transmission in error, please notify this office immediately. EFTA00385816