EFTA02708429

From: Ada Clapp Sent: Tuesday, October 22, 2013 8:23 PM To: Alan S. Halperin; Jeffrey Epstein Cc: Eileen Alexanderson Subject: Re: Timing of Funding GRAT Attachments: Blattmachr-Marital Deduction for Walton GRAT.pdt Untitled attachment 00242.htm Hi =effrey and Alan, I spoke with Leon today and it is =y impression that he wants to wait to fund the GRAT until after the =x-dividend date (so that he can get the dividend and so the value of =hat he transfers to the GRAT will possibly be lower). =nbsp; Regarding the marital deduction issue, =lease Step 3 in the attached article which explains why the productive =f income language is included in the GRAT. Alan--I used to =nclude the following language (one time) in the trust boiler plate =here there was a marital trust included, so I am fine with your =roposed solution. "In the event that any property not productive of income shall be held in any Marital Trust, the Trustees, upon [SPOUSE'S NAMEI's written request, shall make such property productive of income =r shall convert such property into income producing property within a =easonable period of time." New York NY 10019 phone: IRS=Circular 230 Disclosure: Pursuant =o IRS regulations, I inform you that any tax advice contained in this =ommunication (including attachments) is not intended or written to be =sed, and cannot be used by any person or entity for the purpose of (i) =voiding tax related penalties imposed by any governmental tax =uthority, or (ii) promoting, marketing or recommending to another party =ny transaction or matter discussed herein. I advise you to consult with =n independent tax advisor on your particular tax =ircumstances. This communication, =nd any attachment, is for the intended recipient(s) only and may =ontain information that is privileged, confidential and/or proprietary =nbsp;lf you are not the intended recipient, you are hereby notified =hat further dissemination of this communication and its attachments is =rohibited. Please delete all copies of this communication and its =nbsp;attachments and notify me immediately that you have received them =n error. EFTA_R1_02109707 EFTA02708429