EFTA02510489.pdf

From: jeffrey E. <jeevacation@gmail.com> Sent: Sunday, February 22, 2015 9:51 PM To: Brad Wechsler Subject: Re: Fwd: ill do my best to be gentle. however, this is =mbematic, I truly have no idea what she is talking about re phaidon.=mfarlands accounts. papered. ?loans. debt. lots of words =no meaning On Sun, Feb 22, 2015 at 5:27 PM, Brad Wechsler <mailto wrote: Yeah...longform gobbly goop. Let me call u tomor=ow am w/ eileen and rich on ben notes and phaidon. After we understand the=facts, we shld discuss how to proceed. Leon's "instinct"--as an interim step--is for you and i to speak to pwc and mcfarlands to better=understand the "ignore" vs "liquidate" decision with a=bias towards liquidating IF we're comfortable there are minimal issues= (You may have more current info than me.) Also, different subject, he wants to know if $$ go into Phaidon Global as e=uity can we get them out in a tax efficient manner (ie, some sort of retur= of capital vs dividend); we shld look into. At the moment I share your vi=w that simplicity on inter family items very impt.... I'll try to reach u tomorrow am. Also, to state the obvious, next few days we shld be "gentle" wit= eileen.... From: jeffrey E. [mailto:jeevacation@gmail.com <mailto:jeevacation@g=ail.com> Sent: Sunday, Februa 22, 2015 02:15 PM To: Melanie Spinella >; Brad Wechsler Subject: Fwd: Gobbly gook. I have no idea what this means Forwarded message From: Eileen Alexanderson Date: Sunday, February 22, Subject: To: "jeffrey E." .c* v i n mil. m <mail o:'eeva a ion mail.com» Cc: Ada Clap Sorry don't have access from here to check exact amount of note at=time of distribution in 2010 but, from memory, it was approx $7.8 mil. int=rest was accrued but not paid to Ben. It was decided taxes needed to be pa=d in this imputed accrued income•can check tomorrow on who ruled on that subject. In December 2012 the note, with interest, had a value if $8.37 mil. Art before yearend the note was divided into two notes: Note 1 in the amount of $5.12 mil was used to fund Ben's Yggdrasil=Trust ( formed to take advantage of the gift exemption due to concern the =Ilowed level would be reduced.) Note 2 in the amount of $3.25 mil remained in Ben's self settled 2=10 Trust. EFTA_R1_01642246 EFTA02510489 Notes were restructured at yearend 2013. Note used to fund Yggdrasil w=s purchased by the LDB20111LC. The $3.25mi1 was paid off by the same LLC. =ith interest that grew to $3.45mi1. That cash was deployed as I indi=ated earlier, i.e. townhouse+current balance in the trust. Again, this is from memory. Will confirm tomorrow. O= Ada please chime in. Re the Phaidon entities, loan to midco was on paper only, no int=rest paid, by PWC design, it was not supposed to be. Re money flow, =t time of acquisition cash went from Acq LLP through Topco and Midco and t=en to Bidco (JMWT Ltd) but all using MacFarlane's client account and then papered since there was no Acq LLP bank account. A=ain, no access to file from here today, sorry. No tax filings have been ma=e to date. Rich would no better but i believe statutory accounts were file= in January after auditors signed off on the fiscal 2014 statements and John Murphy has BDO addressing tax f=lings currently. They could not do so until these accounts were filed. =A0 Sent from my iPhone On Feb 22, 2015, at 11:06 AM, jeffrey E. <jeevacation@gmail.com&g=; wrote: what was the total note in the begiing? interest, =A0 where did the phantom income come in? did interest get paid. ? =A0 2 can you tell me with topco bidco midco. did money e=er move ? what was debt? which entity , any tax filings = any filings at all? money flowe etc On Sun, Feb 22, 2015 at 11:30 AM, Eileen Alexand=rson rote: $3.25 mil of note was paid off by the LDB2011 LLC. That cash went to B=n's 2010 Trust. Part went toward townhouse purchase and $1.2 mil cash =s still held between the 2010 Trust and Donalbane LLC. $5.2mi1 of note was=purchased by the LDB 2011 LLC ( which is now owned by APO 1) On Feb 21, 2015, at 4:57 PM, jeffrey E. <jeevacation@gmail.com>= wrote: the phantom income generating note to ben, did we get ri= of it entirely? 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. 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