Epstein Secrets

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

vidual, the predeceased child's share of the assets will be paid in equal shams to his or her children then living. U.S. practice conducted through McDermott Will & Emery LLP. DM US 39870777-2.088835.0011 EFTA00586970 3. Remote Takers In the event the survivor of you is not survived by any of Debra's issue, any undi

of Delaware, Administrative Trustee EFTA_R1_01945047 EFTA02672198 Stet) Two: Leon Sells AIF IV Management Inc. to 2011 Trusts For tax reasons, Debra resigns as Trustee from the 2011 Trusts. Each of the the 2011 Trusts purchases from Leon 25% of the stock of AIF IV, valued using CSV of the policie

SPLIT-DOLLAR PROPOSAL of McDermott Will & Emery LLP November 18, 2013 EFTA_R1_01945046 EFTA02672197 Step One: Distribution of BFP Interests (or a cash Loan) to 2011 Trusts The APO1 Trust distribu

s; US Trust Company of Delaware, Administrative Trustee EFTA00583245 Step Two: Leon Sells AIF IV Management Inc. to 2011 Trusts For tax reasons, Debra resigns as Trustee from the 2011 Trusts. Each of the the 2011 Trusts purchases from Leon 25% of the stock of AIF IV, valued using CSV of the policie

SPLIT-DOLLAR PROPOSAL of McDermott Will & Emery LLP November 18, 2013 EFTA00583244 Step One: Distribution of BFP Interests (or a cash Loan) to 2011 Trusts The APO1 Trust distributes (decants) suff

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

a GST tax. Under current law, the GST exemption is $5.12 million. The GST tax is further discussed in II.B, below. U.S. practice conducted through McDermott Will & Emery LLP. 35983468-3.088835.0011 Dhl US EFTA00585838 C. Dispositive Provisions 1. Distributions The trust agreement provides that the trustees of the