EFTA01791812

From: Fenn, Patrick <I M> Sent: Saturday, April 6, 2013 8:29 PM To: 'Eileen Alexanderson'; 'ada.clapp@gmail.com'; 'Thomas Turrin' Subject: FW: Section 734 Attachments: Summary of Scenarios at 7.5% and 100% of Tufts TRA.pdf.zip Hi. The attachment shows that, even under the most favorable conditions in the deferra= context (20 year deferral of tax on Tufts gain but full TRA benefits begin=ing in 21st year at a 7.5% di=count rate), the value of TRA benefit is $16.5 million for Leon. Other than by altering the discount rate and the tax rate=, I don't think the TRA benefit in the deferral (guarantee) scenario will get much b=tter. I will leave to you to determine whether that might be e=ough to overcome the non-tax aspects of the guarantee. Let me know i= you want to discuss.<=p> IRS Circular 230 Notice Requirement: This c=mmunication is not given in the form of a covered opinion, within the mean=ng of Circular 230 issued by the United States Secretary of the Treasury. =hus, we are required to inform you that you cannot rely upon any tax advic= contained in this communication for the purpose of avoiding United States=federal tax penalties. In addition, any tax advice contained in this commu=ication may not be used to promote, market or recommend a transaction to a=other party. The information containe= in this e-mail message is intended only for the personal and confidential=use of the recipient(s) named above. If you have received this communicati=n in error, please notify us immediately by e-mail, and delete the origina= message. 1 EFTA_R1_00122195 EFTA01791812