Epstein Secrets

ty (cane collection, rare book collection, bronzes, etc.). Family Office Good progress made. Need to check with Eileen. 2. Prepare inventory of Debra's personal property, including jewelry. Family Office In progress 7 of 9 EFTA00583496 CHECKLIST FOR LEON BLACK ESTATE PLANNING AND RESTRUCTURIN

ounting of 2006 Trust Raich Complete 5. Prepare Accountings of GRATs A-K Raich Complete 6. Evaluate the extent to which other family members (Debra and the children) should have separate counsel. Team Complete Confirm that John Hannan and Richard Ressler will proceed without separate counsel

ust Agreement. PW Complete but revisions likely 2. Leon to execute Trust Agreement. PW Complete 3. Determine which assets will be decanted to the Heritage Trust (2006 Trust, 1997 non-GST exempt trust, etc.) and the timing. • If 1997 Trust assets, wait until 2009 GRAT terminates? Or assign receivable? Tea

re presumed to mirror those in Leon's documents. • Administration expenses are assumed to be $5 million in Leon's estate and are assumed to be 2% of Debra's probate estate. • Valuation discounts totaling 30% are applied to the value of Black Family Partners. L.P. interests. • The value of the GRATs i

ghest Federal Estate Highest New York Estate Credit Tax Rate Tax Rate 2014 5.340,000 $ 2,081,800 40% 16% Notes and Assumptions: • Leon and Debra are presumed to die in 2014 with Leon immediately predeceasing Debra. • Debra's Will and Revocable Trust provisions are presumed to mirror those in

pal to Debra and Leon's descendants. strata to the sienna:on guidelines maned in tie Trust Agreement. After Leon's death. art andtoilet-Wes held in the Heritage Trust designaled for a particular child will be darned to such chiiSs Legacy Tnnl. Alter Debra's death. simitury designaled items in the Marital Trust wa

the Trustees may pay him, income and principal at any time and for any purpose. c. Should Leon become incapacitated, the Trustees may make gifts to Debra, descendants, Judy Black, Shirley Black, and charitable organizations. 3. Upon Leon's Death a. Tangible personal property. Leon is to identify spe

ebra survives, any items identified as part of a child's art collection and held in Debra's marital trust will pass to such child's Legacy Trust at Debra's subsequent death). If a child predeceases Leon leaving descendants, his or her designated art collection will be divided and held in separate Leg

a will receive outright the Manhattan apartments; the remaining residences will be held in her marital trust. If Debra directs property to be sold, the Heritage Trust, followed by the children (or their Legacy Trusts) will have a right of first refusal. ii. If Debra predeceases, the Manhattan apartments will be s

iscounts will "disappear". Assuming no principal repayments, the note value will remain frozen at the discounted value. • The Overview assumes that Debra has transferred title to all residences to Leon. Leon's new Will and Revocable Trust are drafted as if Leon owns all residences individually. In fac

tly in effect. Items to highlight (noted with the last version): • The Overview illustrates the 1997 Trust and the 2006 Trust already decanted into the Heritage Trust. • BFP interests are discounted 30% to reflect the reality of the Note substitution. This deflates the value of Leon's estate (good for estate tax

if the loans that Leon has received from family trusts are repaid in kind with BFP interests or artwork after the death of the survivor of Leon and Debra. However, the "estate administration" exception generally can be utilized to exempt such transactions from the self-dealing rules if such repayments

the Black Family 1997 GST Exempt Trust holds GST tax- exempt assets. Because that trust does not include the more tailored governance provisions of the Heritage Trust, it may be desirable to consolidate the GST exempt assets in a single trust. 6 As of December 31, 2016. 7 In Part III.a. below, we recommend pou

scounts will =disappear". Assuming no principal repayments, the note value =ill remain frozen at the discounted value. • The Overview assumes that Debra =as transferred title to all residences to Leon. =nbsp; Leon's new Will and Revocable Trust are drafted as if Leon =wns all residences individually.

ently in =ffect. Items to highlight (noted with the last =ersion): The =verview illustrates the 1997 Trust and the 2006 Trust already decanted =nto the Heritage Trust. • BFP interests are discounted 30% to reflect =he reality of the Note substitution. This deflates the value of =eon's estate (good for estate tax

) the 2006 Trust Trustees are Leon, John and Richard and (ii) the Trustees of the 1997 Trust are Barry, John, Richard nDebra. Does Leon want to add Debra as a co-Trustee of the the APO1 and APO2 trusts after his death (she is only added as a Trustee of the Marital Trust, if any)? Ada Clapp Black Fa

please confirm October funding as opposed to November (with lower rate). Also, the Trustees listed in the APO I and APO2 trusts are the same as in the Heritage Trust: that is, Barry Cohen, John Hannan and Richard Ressler. Just want to confirm that this is what Leon wants (and not Paul Weiss's assumption when dra

o create Separate Trusts for your descendants (see I B below), all trust property will be held in a single "Discretionary Trust" for the benefit of Debra and your descendants. A. The Trustees have broad discretion to distribute income and principal to Debra and your descendants, but before doing so,

OI GRAT, as well as the assets of the Black 2006 Family Trust upon a decanting of such trust by its trustees. Once you have settled on the terms of the Heritage Trust, it will be the ultimate recipient of the assets held under this Agreement. I. Discretionary Trust. Until such time as the Trustees decide to crea

o create Separate Trusts for your descendants (see I B below), all trust property will be held in a single "Discretionary Trust" for the benefit of Debra and your descendants. A. The Trustees have broad discretion to distribute income and principal to Debra and your descendants, but before doing so,

ets of the Non-Exempt Trust under the Black Family 1997 Trust upon a decanting of such trust by its trustees. Once you have settled on the terms of the Heritage Trust, it will be the ultimate recipient of the assets held under this Agreement. I. Discretionary Trust. Until such time as the Trustees decide to crea