EFTA02448450.pdf

From: Brad Wechsler Sent: Wednesday, October 12, 2016 9:47 PM To: Richard Joslin; Jeffrey Epstein Cc: John Castrucci; Tom Turrin Subject: Re: foreign tax credit Hi rich•as I mentioned to john earlier this is good news; I will want to di=cuss and understand in more detail tomorrow. B Sent from my Verizon Wireless BlackBerry From: Richard Joslin Date: Wed, 12 Oct 2016 21:26:44 +0000 To: jeffrey Neevacation mail.com>• Brad Wechsler Cc: John Castrucci ; Thomas Turrin= Subject: FW: foreign tax credit Good news re foreign t=x credits — general category credits from 2015 should be carried over to=2016 (no carryback to 2014). One caveat and I will not put into emai= (pls call to discuss) Foreign tax credits. 1 year carryback; 10 year carryforward. Credits arise from "general category " income (management=fees) or from "passive category" income (interest/ dividends). 4P> In 2012, all carry forwa=d and current year foreign tax credits were utilized. General category credit =arryback of $456,067 from 2013 (regular tax) and $528,706 (al= min) would have been absorbed into 2012 for regular and alt min purposes.=o:p> General category credit =arryback of $490,837 from 2014 (regular tax) and $196,6=1 (alt min) would not be carried back to 2013 and would be carried over to 2015= (no capacity to absorb in 2013 for regular and alt min p=rposes). All passive category cre=its were utilized in 2013 and 2014. Any unused passive category credit of $143,307 from 2015 would be carried back and absorbed in 2014 (lost if not c=rried back) Unused general category =redit of $1,881,188 from 2015 would not be carried back to 2014 and would be carried over to 2016 &n=sp; Carryover credit from 2014 would be carried over to 2016.40:p> =1p> =Ip> EFTA_R1_01546243 EFTA02448450 Regular tax (2012): Alt min (2012): Regular tax( 2013) Regular tax (2013) — general category — full use=(no capacity to absorb carryback) Regular tax (2013) — passive category (capacity to=absorb carryback passive category credit) Alt min (2013) — full use of general category cred=t AMT 2013 ( capacity to absorb carryback fo passive c=tegory tax credits) 2 EFTA_R1_01546244 EFTA02448451 Regular tax 2014 General category bucket — fully utilized NO capaci=y to absorb carry back Regular tax 2014 Passive bucket (regular) fully use with capacity to =bsorb carryback credit AMT 2014 GENERAL CATEGORY: Capacity to absorb general categor= credit of $196,641 AMT 2014: PASSIVE CATEGORY capacity to absorb unused=passive category credits = 1, 3 EFTA_R1_01546245 EFTA02448452 4 EFTA_R1_0 1546246 EFTA02448453