EFTA02313344.pdf

From: 1 <jeevacation@gmail.com> Sent: Monday, April 1, 2019 3:47 PM To: Karyna Shuliak Subject: Re: Bin Ennakhil I sincerely appreciate your kind response.. =AO 1. The authorites sin Rabat told me the same thing and said they=would reserve the right to charge me the capital gains as well as the tran=fer tax. They said that the vendor is trying to avoid tax and=as it was I that was helping him I should pay what he owes. They sai= that many purchases happen as you suggest but not of such a substantial=C2 property. 2 The directors do not own the co =the shareholder does. so a change in directors is meaningless.=C2 3. AML can be done at the last moment not the first. t=at is silly, I have bought other properties and am intimately famil=ar with the reguations. . Your vendor transfered shares =from a BVI co , to a stiftung. with no paperwork shown to us. =the values were obviously incoorrect. . I dont know what the cost p=ice was of the house so it was difficult to gauge capital gains on profits= I could buy the property and loan the owner the balance on day one=C2 to be repaid over four years as the govt allows. thanks=for you kindness Cc: Mark Lloyd Subje=t: Bin Ennakhil =ear Karyna Alex Peto Please read this but my goal is not to change your decision. I hate to leave a sale process with su=h a bad feeling of the potential buyer. You are an extraordinary wise young wom=n. I could be your grandfather and the owner is ten years older. This might ha=e had an effect on our discussions which started about 6 weeks ago. I flew numerous times to Italy to negotiate different points. Agreeing t=e price reduction from 29 (with an additional building permit for hospitality= still pending) to 23 (for a very quick deal). Following, the ven=ors full point of view The property You visited the property a=d loved this architectural masterpiece. Checking structure and roofs, as you mentioned, is totally right. A survey of heating, cooling, plumbing and electricity (installed with the latest Swiss technology in the early 90s) m=ght show some updates to do even if everything is working. The AML=/span> The AML is a pure American regulation applied worldwide fighting against money laundering. It secures vendor and buyer. The emitting and receiving banks certify that their clien=s are "clean". Two sales failed in the last 24 months for this unique reason and the first step for the vendor and his =ank was to get this AML done. The Due Diligence EFTA_R1_01203132 EFTA02313344 Since 1=90, the property had only one owner, Pamur Anstalt. Directors of Pamur probably changed several times. Is this really important ? As a new owner, Haze Trust would also probably have changed the directors and maybe sold Pamur to another entity.=/span> Taxes in Morocco They are two ways to sell the property, but they can't be mixed. First one: sale of th= property. Pamur Anstalt has to provide the investment balance and pay the capital gain taxes (31%). The vendor rejected this option, as explained. He needs then 4 years to receive the full net amount out of Morocco. Second one: Sale of the Pamur Anstalt shares in Liechtenstein. Haze Trust or any other entity is the shareholder of the Pamur Anstalt, and nothing changes in Morocco, except ne= directors Transferring the ownership of the property to Haze Trust comes back to option 1, with payment of capital gain. Strategically this would be a financial disaster. I enjoy=d to exchange with you, did not play a game between two "competitors" and wish you a happy investm=nt in Morocco. Yours sincerely Marc LEON=/a> Partner KENSINGTON Luxury Properties Sarl <=span> Private Office Marrakech www.kensingtonmorocco.com<=a> <http://www.kensingtonmo=occo.com> <=div> 2 EFTA_R1_01203133 EFTA02313345 =AO please note The information contained i= this communication is confidential, may be attorney-client privileged,=may constitute inside information, and is intended only for the use =f the addressee. It is the property of JEE Unauthorized use, disclos=re or copying of this communication or any part thereof is strictly pro=ibited and may be unlawful. If you have received this communication =n error, please notify us immediately by return e-mail or by e-mail to =a href="mailto:jeevacation@gmail.com" target="_blank">jeevacation@gmai=.com, and destroy this communication and all copies thereof, inc=uding all attachments. copyright -all rights reserved 3 EFTA_R1_01203134 EFTA02313346