EFTA02472575

From: jeffrey E. <jeevacation@gmail.com> Sent: Thursday, February 11, 2016 2:21 PM To: Brad Wechsler Cc: Richard J Bronstein; Melanie Spinella Avantario; Richard Joslin Subject: Re: it says charter revenue only 312 but letter says apo=lo hours were 42 at 18k each hour? ; John Castrucci; Joe On Tue, Feb 9, 2016 at 6:41 PM, Bra= Wechsler wrote: MEMORANDUM ATTORNEY-CLIENT PRIVLEDGE</=> qspan> 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, 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. EFTA_R1_01584619 EFTA02472575 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 J 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_01584620 EFTA02472576