From: Erika Kellerhals

From: Erika Kellerhals To: Jeffrey Epstein <jeevacation@gmail.com> Subject: Re: Date: Fri, 04 Jan 2013 19:26:06 +0000 Inline-Images: 7B8B96A5-A17A-4855-9256-43BDEEA09109[160].png; 7B8B96A5-A17A-4855-9256- 43BDEEA09109[129].png; 7B8B96A5-A17A-4855-9256-43BDEEA09109[123].png III send response — but right now working on tax court petition due today. Erika A. Kellerhals Partner Kellerhals Ferguson Fletcher Kroblin LLP 9100 Port of Sale Mall Suite 15 St. Thomas. U.S. Virgin Islands 00802 Notice: This communication may contain privileged or other confidential information. If you are not the intended recipient. or believe that you have received this communication in error. please do not print. copy. re-transmit. disseminate. or otherwise use this information. Also, please indicate to the sender that you have received this e-mail in error. and delete the copy you received. Thank you. Circular 230: To ensure compliance with the requirements imposed by the IRS. we inform you that any tax advice contained in our communication (including any attachments) was not intended or written to be used, and cannot be used. for the purpose of (i) avoiding any tax penalty or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. From: Jeffrey Epstein <jeevacation@gmail.com> Date: Friday, January 4, 2013 9:38 AM To: Erika Kellerhals < Subject: Re: so what structure would work, for the bank? do i , or do they own the cumalitve preferred, ? what limits , how do they get a tax deferral with little risk On Fri, Jan 4, 2013 at 8:51 AM, Erika Kellerhals wrote: If you own bulk of cs its okay Also depends on types of income company is generating Active vs non-active income Erika A. Kellerhals EFTA00951821 Partner Kellerhals Ferguson Fletcher Kroblin LLP 9100 Port of Sale Mall Suite 15 Notice: This communication may contain privileged or other confidential information. II you are not the intended recipient. or believe that you have received this communication in error, please do not print, copy. re-transmit. disseminate. or otherwise use this information. Also. please indicate to the sender that you have received this e-mail in error, and delete the copy you received. Thank you. Circular 230: To ensure compliance with the requirements imposed by the IRS. we inform you that any tax advice contained in our communication (including any attachments) was not intended or written to be used, and cannot be used. for the purpose of (i) avoiding any tax penalty or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. From: Jeffrey Epstein <jeevacation@gmail.com> Date: Friday, January 4, 2013 8:49 AM To: Erika Kellerhals Subject: Re: so if us residents own common shares in our new bank,? why is my holding of a 100 percent intrest as a us person not included, On Fri, Jan 4, 2013 at 8:32 AM, Erika Kellerhals wrote: An entity incorporated in the USVI is considered a foreign corporation for the purposes of the unmirrored Internal Revenue Code. Therefore, when U.S. shareholders control a USVI corporation under the 50% rule ( U.S. shareholders own more than 50% of the combined voting power of its stock or more than 50% of the total value of the stock) the USVI corporation is treated as a CFC (a "USVI CFC"). To the extent that a USVI CFC invests its earnings in United States property or earns subpart F income in the form of foreign base company sales income, foreign base company services income, or foreign personal holding company income, its United States shareholders are taxed on such investment in United States property and subpart F income to the same extent as if such corporation were formed in a foreign country Erika A. Kellerhals Partner Kellerhals Ferguson Fletcher Kroblin LLP 9100 Port of Sate Mall EFTA00951822 Suite 15 St. Thomas. U.S. Virgin Islands 00802 Notice: This communication may contain privileged or other confidential information. If you are not the intended recipient or believe that you have received this communication in error, please do not print, copy, re-transmit, disseminate, or otherwise use this information. Also, please indicate to the sender that you have received this e-mail in error, and delete the copy you received. Thank you. Circular 230: To ensure compliance with the requirements imposed by the IRS, we inform you that any tax advice contained in our communication (including any attachments) was not intended or written to be used. and cannot be used. for the purpose of (i) avoiding any tax penalty or (ii) promoting. marketing or recommending to another party any transaction or matter addressed herein. From: Jeffrey Epstein <jeevacation@gmail.com> Date: Thursday, January 3, 2013 7:00 PM To: Erika Kellerhals Subject: <no subject> how do the cfc rules apply to us residents holding shares in vi corp. 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 Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation@gmail.com and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 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 Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation@gmail.com and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00951823 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 Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation@gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00951824