EFTA Document EFTA01789598

From: Thomas Turrin Sent: Monday, April 8, 2013 10:28 PM To: Ada Clapp; Elyse G. Kirschner Cc: Eileen Alexanderson; Jeffrey Epstein Subject: RE: Black Family 2012 Gift Tax Reporting Obligations Ada, I agree with you on makin= affirmative allocations of GST. We have always make affir=ative allocations of gst with all relevant details. The gift tax returns will=be on extension. I will send you the drafts of the returns whe= ready. <=p> Best,</=> Torn <=p> <=p> THOMAS TURRIN, CPA<=o:p> Partner Raich Ende Malter & Co. LLP EFTA_R1_00116238 EFTA01789598 <=p> <=p> <=p> From: Ada Clap= [mailto:ada.clapp@gmail.comj Sent: Monday, April 08, 2013 6:19 PM To: Elyse G. Kirschner; Thomas Turrin Cc: Eileen Alexanderson; Jeffrey Epstein Subject: Black Family 2012 Gift Tax Reporting Obligations=/span> Hi Elyse and Tom, I wanted to follow up with you regarding the need to=report the gifts each of Debra, Ben, Josh, Alex and Victoria made to new t=usts they each created in 2012, as outlined in Elyse's attached memorandum= The memorandum implies that the family members will rely on the automatic allocation rules under the Treas=ry regulations for the allocation of GST exemption to their gifts. M= preference is to make an affirmative allocation of GST exemption on the g=ft tax return reporting the gift, where that is the intention, rather than relying upon the automatic allocation r=les. Not only is that the "safer" route, but it avoids con=usion later as to how much GST exemption was used by an individual, as you=have created a record for all involved to refer back to. If you elect to rely on the automatic allocation rul=s, would Elyse kindly confirm that the rules will apply to allocate =ST exemption to 100% of each family member's 2012 gift (e.g., that they ar= indirect skips to "GST trusts" under the regs) . If instead, the gift tax returns will make affirmative =llocations of each family member's GST exemption, I would like the opportu=ity to review the allocation language. Thanks in advance for your response. Best regards, Ada Clapp Black F=mily Partners go Apollo Management 9 W 57th Street 2 EFTA_R1_00116239 EFTA01789599 New York NY 10019 phone: 917-286-5536 email: ada.clapp@gmail.com <mailto:ada.clapp=gmail.com> <=p> IRS Circular 230 Discl=sure: Pursuant to IRS regulatio=s, I inform you that any tax advice contained in this communication (inclu=ing attachments) is not intended or written to be used, and cannot be used by any person or entity for the purpose of (i) avoiding=tax related penalties imposed by any governmental tax authority, or (ii) p=omoting, marketing or recommending to another party any transaction or mat=er discussed herein. I advise you to consult with an independent tax advisor on your particular tax circumst=nces. <=p> This communication, and a=y attachment, is for the intended recipient(s) only and may contain inform=tion that is privileged, confidential and/or proprietary If you are not the intended recipient, you are hereby notified that =urther dissemination of this communication and its attachments is prohibit=d. Please delete all copies of this communication and its atta=hments and notify me immediately that you have received them in error. &n=sp; &n=sp; CONFIDENTIALITY STATEMENT: The information contained in this elect=onic communication, including any and all attachments and enclosures, may be privileged and is strictly confidential, intended s=lely for the use of the person(s) identified above to receive this communi=ation. If you are not the person(s) identified above to receive this commu=ication, you are hereby notified that you may not disclose print, copy, disseminate, or otherwise use the i=formation contained herein. If you are an employee or agent of the person(=) identified above to receive this communication and, as such, you have be=n authorized to deliver this communication to such person(s), you may disclose, print, copy, disseminate, or otherwis= use the information contained in this communication solely for the purpos= of such delivery. Unauthorized interception and/or use of this communicat=on are/is strictly prohibited and may be punishable by law. If you have received this communication in error= please reply and notify the sender (only) of that fact and delete the com=unication, including any and all attachments and enclosures, from your com=uter or other electronic device on which you may have received this communication. 3 EFTA_R1_00116240 EFTA01789600 CIRCULAR 230 DISCLOSURE: To insure compliance with requirements imposed by the Internal Reven=e Service, we inform you that any tax advice contained in this communication (including any and all attachments), unles= expressly stated otherwise, was not intended or written to be used and ca=not be used for the purpose of (i) avoiding tax-related penalties imposed =y the Internal Revenue Code or (ii) promoting, marketing, or recommending to another party any transactio=(s) or tax-related matter(s) addressed herein. This communication may not =e forwarded (other than to the addressee(s) identified above) without our =xpress written consent. 4 EFTA_R1_00116241 EFTA01789601