EFTA00681971.pdf

From: Ada Clapp To: Jeffrey Epstein <jeevacation®gmail.com> Cc: Eileen Alexanderson Subject: Re: 2012 Year End Trust Gifts Date: Tue, 09 Apr 2013 14:08:40 +0000 cza Thanks. We are still waiting to hear back from Akin on AIF IV. I sent Steve Vine another email yesterday morning and have not heard back. I will nudge him again shortly. I believe I prepare a memorandum a while back outlining the split dollar arrangement. I will find it and send it to you as you may find it helpful. I am not sure I understand your question regarding cost basis. Generally, life insurance death benefits proceeds are excludible from the recipient's gross income for Federal and State income tax purposes unless the transfer for value rule applies. That rule would occur where the policy has been sold or transferred for consideration. In that case, the recipient/transferee would have taxable income to the extent that the insurance proceeds exceeded the total purchase price paid for the policy plus any premiums the transferee paid in (these two items make up the purchaser's basis in the policy). Ada Clapp Black Family Partners do Apollo Management 9 W 57th Street New York NY 10019 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 purpose of (i) avoiding tax related penalties imposed by any governmental tax authority, or (ii) promoting, 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. 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. Please delete all copies of this communication and its attachments and notify me immediately that you have received them in error. On Apr 9, 2013, at 9:40 AM, Jeffrey Epstein <jeevacation®gmail.com> wrote: good catches. are we any closer to find a capital account for ap 4 . lid, ? lets review split dollar , silly, ? does insurance cost go to basis? EFTA00681971 On Tue, Apr 9, 2013 at 9:36 AM, Ada Clapp < > wrote: Hi Elyse, I was reviewing our files for the trusts that were signed and funded in December 2012 and found some items with respect to Josh and Ben's planning that I am hoping you can help me with: Ben Cancellation and Reissuance of Promissory Note: • The third paragraph refers to an Agreement to Assume Obligations dated as of June 10, 2011. I understand from Akin Gump that the referenced agreement does not exist as it was replaced with two Assumption Confirmation agreements dated June 10, 2011. Can you make this revision without altering page numbers so we don't need to have John, Debra and Barry re-sign. • The date written in in the fourth paragraph is not correct. I believe that date should be January 16, 2011 (the date Ben originally assigned the note to his 2010 self settled trust). If you agree, can you also make that revision without altering pages? Josh Black 1. Cancellation and Reissuance of Promissory Note: • Exhibit A to this document refers to Ben Black and his trust instead of Josh Black and his trust. Can you please send a revised Exhibit A? 2. Assignment by Josh to the Joshua Max Black 2011 Trust of Promissory Note in the amount of $5,897,726: • The document we have (which is signed by Josh, Leon and U.S. Trust) has an incorrect date for the assignment (December 18, 2011 instead of December 20, 2012) and references the principal amount of the Note as $5,898,510. 3. Promissory Note in the amount of $5.12 MM from the JMB 2011 Trust to Josh: • We cannot find a signed copy of this promissory note. Please let me know if you have already addressed the above as perhaps I do not have the latest documents. Best regards, Ada Clapp Black Family Partners do Apollo Management EFTA00681972 9 W 57th Street New York NY 10019 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 purpose of (i) avoiding tax related penalties imposed by any governmental tax authority, or (ii) promoting, 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. 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. Please delete all copies of this communication and its attachments and notify me immediately that you have received them in error. The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein 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 or by e-mail to and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00681973