EFTA00631143.pdf

From: Richard Joslin To: jeffrey E. <jeevacation@gmail.com> Subject: FW: 2014 Gifts to GRATs (Alan's calculations) Date: Wed, 11 Feb 2015 17:22:55 +0000 Attachments: GRAT_DRAFT_FY_2014.pdf Inline-Images: image001.png; image002.jpg; image003.png GRAT gift piece not being calculated for Tom Turrin. Empire valuations of BFP will be signed off on shortly (ie gift amounts will be finalized shortly) From: Richard Joslin Sent: Wednesday, February 11, 2015 12:22 PM To: 'Hurtado, Christopher L' Cc: Thomas Turrin; Halperin, Alan S; tax Subject: 2014 Gifts to GRATs (Alan's calculations) Chris: Please calculate ESTIMATED gift amounts for the 4 GRATS funded in 2014. Please see attached. Please send your calculations to Tom Turrin as well as myself. As soon as I have the finalized valuations, I will send to you and you can re-calculate FINAL gift amounts. As fyi, very likely there will be no variance and this will not be duplicative work. Thanks RJ Richard Joslin CFO Elysium Management LLC 445 Park Ave Ste. 1401 New York, NY 10022 From: Hurtado, Christopher L [mailto: Sent: Wednesday, September 24, 2014 11:43 AM To: Richard Joslin Cc: Thomas Turrin; Halperin, Alan S Subject: RE: 2013 Gifts to GRATs (Alan's calculations) Rich and Tom, I am attaching the output of our calculations for the 2013 gifts. EFTA00631143 Please do not hesitate to contact Alan or me with any questions. Best, Chris Christopher I.. Hurtado I Associate Paul, Weiss, Rifkind, Wharton & Garrison LLP From: Richard Joslin mailto: Sent: Wednesday, September 24, 2014 9:47 AM To: Hurtado, Christopher L Cc: Thomas Turrin; Halperin, Alan S Subject: FW: 2013 Gifts to GRATs (Alan's calculations) Chris: Kindly send to Tom and pls send cc. Thanks From: Thomas Turrin [mailto: Sent: Wednesday, September 24, 2014 9:40 AM To: Richard Joslin Subject: FW: 2013 Gifts to GRATs (Alan's calculations) Rich, Alan had provided the taxable gift amounts below in April for extension purposes. Do you have the details of the gift amount calculations (per below)? ...re: the $88,811 and $36,709... I didn't see them in the portal. Thanks, Tom From: Halperin, Alan S [mailto: Sent: Wednesda Aril 09, 2014 4:40 PM To: • Thomas Turrin Cc: Subject Re: 2013 Gifts to GRATs Hurtado, Christopher L; Castillo, Carlos The APO1 GRAT funded in October 2013 with a tentative value of $940,000,000, will result in a taxable gift of $88,811.27 (based on a gift of $95 per $1 million). The APO1 GRAT NO. 2 funded in December 2013 with a tentative value of $780,000,000, will result in a taxable gift of $36,709.47 (based on a gift of $47 per $1 million). Please let me know if you need any further information. Alan EFTA00631144 IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. 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. Click Here for More Information Alan S. Halperin Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019-6064 From: Ada Clapp [mato: Sent: Wednesday, April 09, 2014 02:03 PM To: Halperin, Alan S; CPA Thomas Turrin Cc: Eileen Alexanderson < >; Richard Joslin < >; Hurtado, Christopher L Subject: 2013 Gifts to GRATs Hi Alan and Tom, As discussed, we don't have final values for the gift to the APO1 GRAT (created October 25, 2013) or the APO1 GRAT No. 2 (created December 4, 2013) but we have some draft numbers we can work with to give Tom an estimate of the taxable gift. The tentative valuations are as follows: APO1 GRAT: received a 37.75% interest in Black Family Partners tentatively valued at $940,000,000. APO1 GRAT No. 2: receive a 34.53% interest in BFP tentatively valued at $780,000,000. Tom, Alan has offered to calculate the tentative gift to each GRAT based on the above amounts (which are subject to change—but likely not much). Thanks! Ada Clapp Elysium Management LLC 445 Park Avenue Suite 1401 IRS Circular 230 Disclosure: Pursuant to IRS regulations, I inform you that any tax advice contained in this communication (including attachments) is not intended or written to be used, and cannot be used, by any person or entity for the purposes of (i) avoiding tax related penalties imposed by any governmental tax authority, or (ii) proposing, marketing or recommending to another party any transaction or matter discussed herein. I advise you to consult with an independent tax advisor on your particular tax circumstances. EFTA00631145 This communication and any attachment is for the intended recipient(s) only and may contain information that is privileged, confidential and/or proprietary. If you are not the intended recipient, you are hereby notified that further dissemination of this communication and its attachments is prohibited. 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