EFTA Document EFTA01457974

property, states in part: 'Moneys, credits, securities and other intangible personal property within the state not employed in carrying on any business therein by the owner shall be deemed to be located at the domicile of the owner for purposes of taxation (italics added]." In other words, the opinions reflect Tax Department policy that doesn't necessarily square with the literal language of the underlying law. Stated differently, the opinions are designed to have a chilling effect, and seem to represent New York's litigating position — namely, that a single member LLC/disregarded entity holding New York real estate will not insulate that real estate from New York estate tax at the non-resident owner's death. This is a point that a wealthy non-resident decedent's estate might be willing to contest. Nevertheless, that same non-resident might prefer to avoid the issue entirely, and perhaps buy a cooperative apartment instead (a co-op is intangible property), or seek a more complex ownership structure for the condo. August 7520 rate The IRS has issued the August 2015 applicable federal rates: the August 7520 rate is 2.2%, the same as July's 7520 rate. The August mid-term rates are: 1.82% (annual). 1.81% (semiannual and quarterly) and 1.80% (monthly). The July mid-term rates were: 1.77% (annual), 1.76% (semiannual and quarterly) and 1.75% (monthly). Blanche Lark Christerson is a managing director at Deutsche Asset & Wealth Management in New York City, and can be reached at blanche.christerson@dt).com. The opinions and ar,-dynes expressed herein are those of the author and do not necessarily reflect those of Deutsche Bank AG or any affiliate thereof (collectively. the 'Bente). Any suggestions contained herein are general. and do not lake into account an inciadual's specific circumstances or applicable ft:veining law. which may vary from ii.arsdiction to jurisdiction and be subject 10 change. No warranty or representation. express or implied. is made by the Bank. nor does tie Bar* accept any liability with respect to the information and data set forth herein The information contained herein is not intended to be. and does not constkute. legal, tar, accorraing or other professional advice: a is also not intended to otter penalty protection or to promote. market or recommend any transaction or matter addressed herein. Recipients should consult chair applicable professional advisors prior to acting on the information set forth !mein The≤ material may not be reproduced withca the cypress permission of the author. "Deutsche rae.‘na Deutsche Bank AG and its affiliated companies. Deutsche Asset & Wealth Management represents the asset management and wealth marssenient activities conducted by DelltSeb? Bare. AG or its subseiranee Cents are provided Deutsche Asset .5 Wealth Management products Or services by ore or more gcti entities thV are identified to clients pursuant to the contracts, agreements. offering mater ale or other documentation relevant to such products or services. Trust and estate and wealth planning services are parceled though Deutsche Bank Trust Company. NA.. Deutsche Bank Trust Company Delaware and Detesche Bank National Trust Company 2015 Deutsche Asset S Wealth Management. All rights reserved. 021744 073115 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0 117712 CONFIDENTIAL SDNY_GM_00263896 EFTA01457974