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e DRB 2012 Family Trust Agreement and the anticipated tax consequences of certain of its provisions. I. The DRB 2012 Family Trust A. Trust Fund Debra will be the creator of the trust. It is anticipated that she will transfer assets valued at an amount equal to Debra's remaining gif tax credit to t
he assets remaining in the trust at the death of the survivor of you (including all appreciation on the original gift) should pass to the trusts for Debra's issue without federal or New York estate tax. D. Income Tax During Debra's lifetime, the primary trust will be a grantor trust. This means that
e tax purposes, the trust may use Debra's social security number as its taxpayer identification number. As part of its effort to curb tax shelters, the Internal Revenue Service has issued regulations that impose sanctions on attorneys who provide informal written tax advice without prominently disclosing that the advice ca
bed below. B. Dispositive Provisions 1. Distributions The primary trust provides that the trustees must distribute as much of the trust fund to Debra and the settlor's issue' as the independent trustees determine for any reason. I For all purposes of the trust agreement, the settlor's issue inclu
x on distributions received from the trust to the extent of his or her share of the distributed income. As part of its effort to curb tax shelters, the Internal Revenue Service has issued regulations that impose sanctions on attorneys who provide informal written tax advice without prominently disclosing that the advice ca
ubject: it appears many if not all of leons gifts were made from a joint bank acct. ? were you aware of this, ? isn't half the gift attributable to Debra? The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is int
ther electronic device on which you may have received this communication. CIRCULAR 230 DISCLOSURE: To insure compliance with requirements imposed by the Internal Revenue Service, we inform you that any tax advice contained in this communication (including any and all attachments). unless expressly stated otherwise, was not i
ubject: it appears many if not all of leons gifts were made from a joint bank acct. ? were you aware of this, ? isn't half the gift attributable to Debra? The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is int
ther electronic device on which you may have received this communication. CIRCULAR 230 DISCLOSURE: To insure compliance with requirements imposed by the Internal Revenue Service. we inform you that any tax advice contained in this communication (including any and all attachments). unless expressly stated otherwise. was not i
971896 it appears many if not all of leons gifts were made from a joint bank acct. ? were you aware of this, ? isn't half the gift attributable to Debra? The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is int
ther electronic device on which you may have received this communication. CIRCULAR 230 DISCLOSURE: To insure compliance with requirements imposed by the Internal Revenue Service, we inform you that any tax advice contained in this communication (including any and all attachments). unless expressly stated otherwise. was not i
ubject: it appears many if not all of leons gifts were made from a joint bank acct. ? were you aware of this, ? isn't half the gift attributable to Debra? The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is int
her electronic device on which you may have received this communication. CIRCULAR 230 DISCLOSURE: To insure compliance with requirements imposed by the Internal Revenue Service. we inform you that any tax advice contained in this communication (including any and all attachments). unless expressly stated otherwise. was not i
ent: Friday, November 16, 2012 5:34 PM To: Kirschner, Elyse Subject: RE: Leon Black - form 709 Elyse, The p/w is my office z=p code. I will send Debra's =n Monday. EFTA_R1_02098708 EFTA02706099 Best, Tom THOMAS TURRIN, CPA Partner Raich Ende Malter &= Co. LLP 1375 Broadway New York, New Yo
her electronic device on which you=may have received this communication. CIRCULAR 230 DISCLOSURE: To insure compliance with requirements im=osed by the Internal Revenue Service, we inform you that any tax advice contain=d in this communication (including any and all attachments), unless expres=ly stated otherwise, was not
ubject: it appears many if not all of leons gifts were made from a joint b=nk acct. ? were you aware of this, ? isn't half the gif= attributable to Debra? The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is inte
er electronic device on which you=may have received this communication. CIRCULAR 230 DISCLOSURE: To insure compliance with requirements imp=sed by the Internal Revenue Service, we inform you that any tax advice con=ained in this communication (including any and all attachments), unless expressly stated otherwise, was not
are made from the Wells Fargo account of Avioneta. Avioneta Holdings, LLC would be the reporting entity for tax purposes, which is owned by Leon and Debra. We will provide Rich J. with what is needed to roll forward the books and records for 2013. See you Thursday. Tom EFTA_R1_02152690 EFTA02716319
her electronic device on which you may have received this communication. CIRCULAR 230 DISCLOSURE: To insure compliance with requirements imposed by the Internal Revenue Service, we inform you that any tax advice contained in this communication (including any and all attachments), unless expressly stated otherwise, was not
move the situs of administration and governing law of the Family Trust from New York to Delaware. It is intended that while at least one of you and Debra is alive and competent, the Family Trust will be a so-called "directed trust." This means that U.S. Trust Company of Delaware ("U.S. Trust"), which
al with future circumstances. Tax Consequences A. Gift Tax Any gift you make to the trust will be a taxable gift and will need to be reported to the Internal Revenue Service on a gift tax return. . B. Generation-Skipping Transfer Tax The generation-skipping transfer ("GST") tax generally is imposed, in addition to any
Entities connected to both Debra and the Internal Revenue Service

Jeffrey Epstein
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JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSONLeon Black
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Alan Dershowitz
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United States
LOCATIONEileen Alexanderson
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Justin Trudeau
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Barry Diller
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Bank of America
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Michael Cohen
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Melanie Spinella
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George W. Bush
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Marc Rich
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Prince Andrew
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PERSONDarren Indyke
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Joe Biden
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Lesley Groff
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