EFTA00713264.pdf

From: Eileen Alexanderson To: 'Jeffrey Epstein' <jeevacation®gmail.com> Subject: RE: Date: Fri, 17 Aug 2012 20:05:22 +0000 New version of the proposal from Carlyn involves amending to make income right a 'fixed right' This should address issue of whether right is giftable Amend, also, so that the Remainder, at time of death, passes to a new trust instead of staying in the 2006 trust LB purchases the income rt and the remainder interest in exchange for promissory note This helps avoid the risk of inclusion we would have had using a GRAT. However purchase of such an asset with implication re disclosures that would need to be made are a concern regarding scrutiny and SEC disclosures Alan still feels GRAT is the way to go but after making right a fixed one. Second subject-Alan and Ada both dislike the Art Partnership in its proposed configuration. Alan has a new proposal as follows: Let's assume we do the GRAT and at its termination it pours into a new 2012 Trust and the assets of the 2006 Trust are decanted into the 2012 Trust also. Instead of having one class of interests in this partnership, there would be two: a pfd class with a coupon and a common class with all other rights including the right to use the art. Leon would own the pfd class, the Trusts would own the common class Example: Leon contributes $1bil Art The 2012 Trust contributes income producing property-namely interests in Black Family Partners with $1bil value at a coupon of 7% (tbd), Leon would receive income of $70miVyr No issue re Leon's control given the fixed coupon Character of the income he gets would not be tied to the income right. Debra, as bene of the Trust can enjoy the art No issue in terms of Leon needing to make redemptions from the partnership Headed for the train out east. Can email re all this once I am on. From: Jeffrey Epstein Imailto:jeevacation@gmall.com] Sent: Friday, August 17, 2012 1:57 PM To: Eileen Alexanderson; Melanie Spinella Subject: to make a gift , you have to have a property right in it. the future income right, is questionalble , the income tax issues, seperate from the gift and transfer tax issues are also complex as gifting incentive fee income is extremely fact specific control etc. 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 EFTA00713264 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 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 EFTA00713265