3
Shared Docs
3
Same-Page
4 / 3
Mentions
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
tponed by the independent trustees for good cause, such as serious illness, creditor issues, a pending divorce or the like. Each trust will end on the Primary Beneficiary's death. Upon termination, any remaining assets will be paid to the Primary Beneficiary's issue then living, or if the Primary Beneficiary has no iss
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
stponed by the independent trustees for good cause, such as serious illness, creditor issues, a pending divorce or the like. Each trust will end on the Primary Beneficiary's death. Upon termination, any remaining assets will be paid to the Primary Beneficiary's issue then living, or if the Primary Beneficiary has no iss
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
rustees, in their sole discretion, determine. The trustees are directed to approve distributions from the trust, by way of example, to cover any of the Primary Beneficiary's medical expenditures, or to help the Primary Beneficiary purchase or finance a home, pay for a wedding or start a business, provided, however, that
Entities connected to both Debra and the Primary Beneficiary's

Jeffrey Epstein
PERSONLeon Black
PERSONEileen Alexanderson
PERSON
Barry Diller
PERSON
Michael Cohen
PERSONElyse G. Kirschner
PERSONRichard Ressler
PERSON
the Internal Revenue Service
ORGANIZATION
Samantha Power
PERSONFamily Trust
ORGANIZATIONDM US
ORGANIZATIONMcDermott Will & Emery LLP
ORGANIZATIONInternal Revenue Service Circular
ORGANIZATION
JPMorgan Chase
ORGANIZATIONTrusts
ORGANIZATION
Joshua
PERSONliving,2
ORGANIZATION