EFTA02473269.pdf

From: jeffrey E. <jeevacation@gmail.com> Sent: Wednesday, February 10, 2016 1:03 PM To: Brad Wechsler Cc: Richard J Bronstein; Melanie SpineIla Avantario; Richard Joslin Subject: Re: John Castrucci; Joe again!!!! ??? bad numbers. h=w can the top line read fuel per hour cost as 975? if right un=erneath it says 528 gallons per hour , and the fuel price is l=sted at between 3 and four dollars per gallon. On Tue, Feb 9, 2016 at 7:41 PM, Br=d Wechsle MEMORANDUM ATTORNEY-CLIENT PRIVLEDGE4=> =/span> TO: =AO Rick Bronstein =AO =C2 =AO CC: =C2 John Castrucci =C2 Leon Black =AO =C2 =AO =C2 =AO Joe Avantario<=p> =C2 =AO =C2 =AO =C2 =AO =C2 Rich Jos=in FROM: Brad Wechsler =C2 =AO =C2 =AO =C2 Jeffrey Epstein DATE: February 9, 2016=/u> Leon, > wrote: EFTA_R1_01585591 EFTA02473269 1. Attached, please find the =anuary 26th memo on the airplane which was sent to you previously. It deal= with Part 91 vs. 135 and attendant costs and income tax benefits. The office feels that with respect to income tax,=Part 135 is more favorable, but not significantly so, i.e., between 0 and $400K depending on use. 2. Also included are detailed=operating costs. These were previously sent to Jeffrey but not previously =ot sent to you. 3. The final note details the=FET and sales tax consequences of moving from the current structure to a s=mplified structure. Were we to move to a very simple Part 91 only structure you could likely save $200K/year but wo=ld have to own and operate the plane in your personal name (your insurance=is sufficient, but there would be a certain lack of privacy). If you held =he plane in a sole purpose LLC the aforementioned savings would disappear. If Jeffrey wants to take a dee= dive, we have much detailed material and we would also suggest he speak t= Rich., and our aviation attorney. 4. Bottom-line, a lot of work=has been done and there is not a compelling answer, one way or another. Ta=ing into account income tax attributes, sales tax attributes and ease of use attributes it's almost a push= though I would probably marginally favor Part 135. I believe Jeffrey favo=s Part 91, which in my mind, is a sufficient reason to go that route. We s=ould discuss. Thanks please =ote The information contained in this communication is confiden=ial, may be attorney-client privileged, may constitute inside informati=n, and is intended only for the use of the addressee. It is the propert= of JEE Unauthorized use, disclosure or copying of this communica=ion or any part thereof is strictly prohibited and may be unlawful. If =ou have received this communication in error, please notify us immediat=ly by return e-mail or by e-mail to jeevacation@gmail.com <mailto:jeevacation@gmail=com> , and destroy this comm=nication and all copies thereof, including all attachments. copyright -=11 rights reserved 2 EFTA_R1_01585592 EFTA02473270