EFTA00708102.pdf

From: "Barry J. Cohen" < To: jeffrey E. <jeevacation@gmail.com> Subject: Re: Planning Date: Sat, 19 Aug 2017 15:12:14 +0000 We think we have examined it extremely carefully. Ada, Paul Weiss, S&C. We are open to the possibility that we are missing something, but no one has been able to say what that might be. Sent from my iPhone On Aug 19, 2017, at 10:23 AM, jeffrey E. <jeevacation@gmail.com> wrote: re planning tool' sorry, no one has fully examined the issues. saying clats in low interest environments make sense is an of course. it is. but ..,. anyway im aval to talk tues On Sat, Aug 19, 2017 at 10:13 AM, Barry J. Cohen < > wrote: > Apollo flight is one that qualifies for Apollo reimbursement and Apollo pays for. > Pro forma depends on when Apollo gives us data. Hopefully very soon. > Gift tax case wasn't "advice". Just a blurb Joe read in a publication. He might well have got it wrong. It was just something he thought he remembered and mentioned in passing. He was making the point that it might be a bad idea for a tax return to have info that is factually wrong even if the tax is right. Whether the case exists or not, that advice hardly seems crazy. > Joe V is the best person we saw and is doing a great job. We have hired top lawyers and accountants. Always glad to see better people but we are not finding them. And very hard to find jacks of all trades. We tend to see narrow expertise. > S&C reviewed our estate planning and basically said everything we are doing is fine. EY reviewed our income tax planning and has been helpful, but has not had great suggestions for changing anything. > If you see specific things we should be doing differently let us know what they are. If you know of people who will have greater insight than the ones we are using, we are eager to talk to them. > I too wish Leon would sell more art. We may have losses to partially offset art gains. To the extent we do not, as you have pointed out, getting a step up on death may be preferable for the pieces with gain. In any event, we don't know if Leon is willing to sell. So we cannot plan around that. My goal is to be able to tell him "If you sell certain art you will achieve the following benefits." Not quite there yet. > On the CLATs, I hear you that no one has experience with art. But as you have pointed out, Leon's situation is unique. Unless we hear specific reasons why it doesn't work it is hard to ignore the unanimous chorus of opinions that it is a sound planning tool. > Sent from my iPhone > On Aug 19, 2017, at 7:44 AM, jeffrey E. <jeevacation@gmail.com<mailto:jeevacation@gmail.com>> wrote: EFTA00708102 > what is an apollo flight . ? when will we have the proforma ? the gift tax paid but still fraud fable is just that . cant be found because it doesnt exist. you are getting childish advice and data. ? sorry. I was very clear with leon that you need a senior tax advisor . person. Joe V is not it. you have bookkeepers , accountants and enad y compliance. you going around to others to see how they work is in my opinion the height of silliness. I consider you tthe best thing that happened to elysium . and have been quite vocal about it. hire the best people . they cost money. This biz is leons most important asset that he will leave to his kids. . It will be responsbile for a whole host of family , estate. operating issues.. > i have not gottten involved in the documentation , of what is there . and its acccesibility. i would guess pretty good now. For ex , my disccusions with other clients are a give and take , of laws mecahnisms. tactics strategys.. audit prep. . case law.. a joint composition of high level planning . reporting. analyisis, alternatives. hearing about an article that your guy might have read in his dentitst office. that turns out to be bogus. is emblematic of the office. I am confient that you will grow into the job, . re clats I only asked if any of your so called advisors have actually done one so they understand its true and pracitcal pitfalls. your response that the art will be sold quickly. and that there is a chapter in lerners book about it , the same book that leon relied on to his detriment before. ( 1031 ) . was suprising, . if the art is to be sold quickly ( not sure leon would sign on. ) , DO it before he dies. not after. art delays the closing of the estate. leon is the "BEST seller. , know the market etc. gains can be dealt with . > I real tax advisor should demand at least 1m per year. up to 3 . all the big firms have a mandatory retirement at age 60. high level people all on the street. my friends biz that only grosses 60 m just hired one for a million. guys that have hand filled out PERSONAL tax returns TRUST returns . planned strategies years in advance. . Audit experience preferable large case. . some tax court experience helpful. . filled out estate tax docs ( VERY IMPORTANT ) > On Sat, Aug 19, 2017 at 7:20 AM, Bany J. Cohen < kmailto:bc > wrote: > Some trips for Apollo are not 135 compliant due to minor issues of crew rest or otherwise. So occasionally we have to fly Part 91 on Apollo flights. Hard to do without Apollo being operator. > Sent from my iPhone >> On Aug 18, 2017, at 10:57 PM, Jeffrey Epstein <jeevacation@gmail.com<mailto: jeevacation@gmail.com>> wrote: » Apollo? >>> On Aug 18, 2017, at 10:56 PM, Barry J. Cohen < kmailto:bc > wrote: >» >>> We are factoring this into our structure recommendations. Lots of constraints. Apollo doesn't want to be an owner or an operator. Makes 91 operations for Apollo tricky. >» >>> Sent from my iPhone >» >>> On Aug 18, 2017, at 8:23 PM, jeffrey E. <jeevacation@gmail.com<mailto:jeevacation@gmail.com> <mailtojeevacation@gmail.com<mailto:jeevacation@gmail.com>>> wrote: >» >» ex >» Forwarded message >» From: Melanie Spinella <mailto: kmailto: <mailto: >>> Date: Thu, May 21, 2015 at 2:54 PM >>> Subject: Plane >>> To: "jeffrey E." <jeevacation@gmail.com<mailto:jeevacation@gmail.comkmailto: jeevacation@gmail.com<mailto:jeevacation@gmail.com>>> EFTA00708103 >>> >>> >>> Jeffrey — Leon asked me to ask you. Debra is going to Chicago May 30th — back and forth the same day. Here is the response from Jet >>> >>> Hi Melanie, >>> >>> For May 30th with the 12pm departure out of Teterboro and 1 1pm departure out of Chicago the duty day is at 15hrs18min. For 135 trips crew cannot exceed 14hr duty day. If you wish to operate this flight as 135 we must do a crew swap in Chicago. If we were to operate this fight as 91 with a Chief Pilot approval we could extended the duty day to 16hrs. Please let me know how you wish to proceed. >>> >>> Can we switch to 91 — Here is what they said about the difference: >>> >>> When operation 91 the owner has operation control and we have a little bit of flexibility with extending the duty day as long the chief pilot approves it. >>> When operation 135 its consider business and the rules are a lot stricter. We are not able to extend the duty day. Two pilots can only be on duty up to 14hrs and no more than 10hrs of flight time. >>> Thank you! >>> >>> Melanie Spinella I Apollo Management >>> 9West 57th Street, New York, New York 10019 >>> • (212) 515 3320<tel:(212)%20515-3320> (Lan)l • (212) 515 3261<tel:(212)%20515-3261> (Fax) >>> •:l mailto: mailto: mailto: >>> Executive Assistant to Leon D. Black >>> This email and any files transmitted with it are confidential and intended solely for the person or entity to whom they are addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other than the intended recipient is prohibited. If you have received this email in error please contact the sender and delete the material from any computer. Apollo Global Management, LLC >>> >>> >>> >>>-- >>> please note >>> 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 >» JEE >>> 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 jeevacation®gmail.conailto:jeevacation®gmail.comxmailto:j <mailto:jeevacation@gmail.com>>, and >>> destroy this communication and all copies thereof, >>> including all attachments. copyright -all rights reserved >>> This email and any files transmitted with it are confidential and intended solely for the person or entity to whom they are addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other than the intended recipient is prohibited. If you have received this email in error please contact the sender and delete the material from any computer. Apollo Global Management, LLC EFTA00708104 > This email and any files transmitted with it are confidential and intended solely for the person or entity to whom they are addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other than the intended recipient is prohibited. If you have received this email in error please contact the sender and delete the material from any computer. Apollo Global Management, LLC > please note > 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 > JEE > 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 jeevacation®gmail.com<mailto:jeevacation®gmail.com>, and > destroy this communication and all copies thereof, > including all attachments. copyright -all rights reserved > This email and any files transmitted with it are confidential and intended solely for the person or entity to whom they are addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other than the intended recipient is prohibited. If you have received this email in error please contact the sender and delete the material from any computer. Apollo Global Management, LLC please note 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 JEE 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 jeevacation®gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00708105