EFTA00601570.pdf

5 Kellerhals Ferguson Kroblin Dux July 16, 2014 Via Email: \I Ms. Marcia Murrell Supervisory Entry Specialist Customs & Border Protection Ron de Lugo Federal Building & Courthouse 5500 Veterans Drive, Room 248 St. Thomas, VI 00802 Mr. Louis W. Harrigan Area Port Director U.S. Customs and Border Protection Ron de Lugo Federal Building & Courthouse 5500 Veterans Drive, Room 248 St. Thomas, VI 00802 Re: LSJE. LLC IV Dear Ms. Murrell & Mr. Harrigan: I am counsel to LSJE, LLC, a U.S. Virgin Islands limited liability company beneficially owned by Mr. Jeffrey Epstein. I understand that concerns have been raised by your agency, U.S. Customs & Border Protection, as to whether LSJE, LLC is engaged in a trade or business, for example, by holding Little St. James out for rent to the public, and whether imported items are being brought into the Virgin Islands by LSJE, LLC for commercial use. I have addressed each of your concerns below: 1. LSJE, LLC is not engaged in a trade or business, and, in fact, has neither applied for nor has it ever been required to obtain a business license. LSJE, LLC is not engaged in a trade or business. It was formed solely for the purpose of providing liability protection to its beneficial owner, Mr. Epstein, in running Mr. Epstein's personal household and residence known as lade St. James. LSJE, LLC is treated as a disregarded entity for tax purposes, receives absolutely no income and incurs no gross receipts tax obligations. There was no profit motive behind the formation of 1 SJE,1,1,C and there is none in the conduct of its affairs. Although Virgin Islands Code, Title 27, section 301 of the Virgin Islands Code requires that every person or association wishing to engage in any business, occupation. profession, or trade must obtain a business license, LSJE, LLC is not required to obtain a business license because it is not engaged in any business and is, therefore, exempt from the requirement to obtain a business license. EFTA00601570 Letter to Marcia Murrell & Louis W. Harrigan July 16, 2014 Page 2 2. Little St. James is not a vacation rental property and is the personal residence of its owner. I have been made aware that your agency has performed Internet searches to determine whether or not LSJE, 1..1A: is engaged in a commercial enterprise. Your agency has directed us to : Hill: as evidence that Little St. James is actually a vacation rental property. Little St. James is not a vacation rental property. As stated above, it is the primary personal residence of its beneficial owner, Mr. Jeffrey Epstein, and is not leased to third parties. With respect to the particular website noted above, that website is from 1997. Mr. Epstein purchased the island in 1998, at which dine it became his primary residence. Our client has made numerous attempts to get the listing removed from this particular website but has been unsuccessful in its attempts thus far. 3. All of the items being imported arc for personal use. All of the items brought in ate for the personal use of the owner. The property being furnished is a seventy- five (75) acre estate with multiple indoor and outdoor living areas. The types and amount of property being imported is consistent with the use, maintenance and operation of a personal residence of that size. Should you have any questions or need additional information, please do not hesitate to contact me at the number listed above. Very truly yours, Erika Kellerhals Enc. cc: Daphne Wallace via email EFTA00601571 • LSJE, LLC 6100 Red Hook Quarter B3 St. Thomas, USK 00802 April 2, 2013 Government of the U.S. Virgin Islands Bureau of Internal Revenue St. Thomas, V.I. 00802 Re: LSJ Employees, LLC 66.0776615 Name Change Dear Madam/Sirs: Please be advised that effective March 13, 2013 the above referenced Limited Liability Company duly organized and existing under the laws of the United States Virgin Islands amended its Articles of Organization to reflect a change of name from LSJ Employees, LLC to LSJE, LW. The Company is attaching an Updated Form 8832 for the sole purpose of reflecting the Company Name Change. LSJE, LLC 6100 Red Hook Quarter, B3 St. Thomas, USVI 00802 If you have any questions please contact Jeanne Brennan at 775-2525. Sincerely yours, Jeanne Brennan Manager Attachment: Form 8832 CC: Atty. Tamarah Smalls RECEIVED PRocEssiNee ACCOUNTS NO to APR 0 2 2013 V IRON ISLVDS BUREAU OP ecrntrim.REVFIsilt Sr. momAs EFTA00601572 Form 8832 (Rev. January 2012) - f81332.pdf hdp://www.irs.gov/pub/irs-pdf/f8832.pdf p.8832 Pee January 2012) ~raw% ol u• Ss** r Weave Reapo reoan Entity Classification Election OMB No. 1545-ISIS TYPO Or Print Nair. ol Menlo inlay Mal" ~Ion kS.J-e, Ain LE"Pb7,°-""c277'7ent„ Nunlbac. Met.« Morn Of Mt CO. it al P.O. box. tea lost/boon& &I OD Led Nook aac,eler_ 43 PAY a 'oral Pau and Wads. • kn011 afros. enter uty. province Or stele. postal cone ana costuy folke the country's practice tor anteing Ina postal code FACIMQ‘„ ni L/6 V/ C >Check it W/Address change LI Late classification rettet sought under Revenue Procedure 2009-41 Rettet for a late change of entity classification election sought under Revenue Procedure 2010-32 Ina Election Information 1 Type of election (see Instructions): a n Initial classification by a newly-formed entity. Skip lines 2a and 2b and go to line 3. b 0 Change In current classification. Go to line 2a. 20 Has the eligible entity previously filed an entity election that had an effect ve date within the last 60 months? 0 Yea. Go to line 2b. 0 No. Sigp line 2b and go to line 3. 2b Was the eligible entity's prior election an initial classification election by a newly tarred entity that was effect've on the date of formation? K Yea. Go to he 3. CI No. Stop here. You generally are not currently eligible to make the eiection (see Instructions) 3 Does the eligible entity have more than one owner? 0 Yes. You con elect to be °ossified as a partnership or an association taxable as a corporation. Skip line 4 and go to line 5. I.WNo. You can elect to be classified as an assocation taxable as a corporation or to be disregarded as a separate notify Go to line 4. 4 If the ettgifte entity has only one owner. provtre the folowing Information: a Name of owner P c.FrrcieE , n b Identifying number of ovmer P % 5 If the eligible entity Is owned by one or more affiliated corporations that file a consolidated return. provide the name and employer identification number of the parent corporation: a Name of parent corporation ► b Employer Identification number P For Paperwork Reduction Act Notice, Oa Instruction°. on No. 2224/A Parnoln2pal-zoim O1 7 4/2/201310:38 AM EFTA00601573 Form 8832 (Rev. January 2012) - f8832.pdf http://www.irs.gov/pub/irs-pdf/f8832.ixlf FORA Sa32tney. 1.2012) LAW faction Information (Continued) Type of entity (see Instructions): Pogo 2 • ri A domestic eligible entity electing to be classified as an association taxable as a corporation. b jfi domestic eligible entity electing to be classified as a partnership. c I A domestic eligible entity with a single owner electing to be disregarded as a separate entity. d K A foreign eligible entity electing to be classified as an association taxable as a corporation. e 0 A foreign eligible entity electing to be classified as a partnership. f 117 A foreign eligible entity with a single owner electing to be disregarded as a separate entity. 7 If the eligible entity a created or organized in a foreign Jurisdiction, provide the foreign country of organization Illo 8 Election is to be effective beginning (month, day, yea) (see instructions) I" ,. _ /0 Q 71 / I 9 Name and the of contact person whom the IRS may call for more Information 10 Contact person's telephone number r le- LI Kc Ao L I a m. / r 9O Consent Statement and Signature(s) (see Instructions) Under penalties of perjury, I (we) declare that I (we) consent to the election of the above-named entity to be classified as Indicated above, and that I (we) have examined this election and consent statement, and to the best of my (our) knowledge and belief, this election and consent statement are true, °affect, and complete. If i em an officer, manager, or member signing for the entity, I further declare under penalties of perjury that I am authorized to make the electron on its behalf. SIgnature(s) Date Title 3 rani 8832 (net 1.2312) of 7 4(2/2013 10:38 AM EFTA00601574