Epstein Secrets

ator would be the number of days held by the charity and the denominator would be 365. But we would need to investigate further. Under current TRA, Tufts gain gives rise to TRA rights only if the gain is triggered in connection with an exchange. Here, the Tufts gain would be triggered by the contribut

ave its debt assumed or transferred. The lender is not making any transfer, as is the case in your most recent email. Again, Rick may have a view. Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019-6064 > I www.paulweiss.com<http://www.paul

From: Halperin, Alan S < Sent: Wednesday, February 24, 2016 12:10 PM To: Jeffrey E. Cc: Bronstein, Richard J Subject: RE: Re: But your example is not our facts. A

From: Halperin, Alan S < Sent: Wednesday, February 24, 2016 12:10 PM To: Jeffrey E. Cc: Bronstein, Richard J Subject: RE: Re: But your example is not our f

ator would be the number of days held by the charity and the denominator would =e 365. But we would need to investigate further. Under current TRA, Tufts gain gives r=se to TRA rights only if the gain is triggered in connection with an excha=ge. Here, the Tufts gain would be triggered by the contribut

From: jeffrey E. <[email protected]> Sent: Wednesday, February 24, 2016 12:04 PM To: Halperin, Alan S Subject: Re: Re: if i owe you money and now i owe joe shmoe because he boug=t your note. i dont see any gain rec On Wed, Feb 24, 2016 at

r company. I suspect that a=y such assumption by another party would give rise to gain at that time. I have copied Rick to get his reactio=. Alan Alan S. Halperin I Partner Paul Weiss Rifkind Wharton & Garrison LLP I New York, NY 10019-6064 (Direct Phone) I Fax www.paulweiss.com <http://www.paulweiss.com>

From: jeffrey E. <[email protected]> Sent: Wednesday, February 24, 2016 12:04 PM To: Halperin, Alan S Subject: Re: Re: if i owe you money and now i owe joe shmoe because he boug=t your note. i dont see any gain rec On Wed, Feb 24, 2016 at 12:56 PM

othing inherit in the laws that govern donor advised fund= which would prohibit such a contribution. However, such a contribution wo=ld trigger the Tufts gain. Further, the donor advised fund would have taxable income, as the AOG units will gi=e rise to UBTI. Under the current TRA, the Tufts gain, unl

From: jeffrey E. [mailto:[email protected]] Sent: Tuesday, February 23, 2016 4:51 PM To: Halperin, Alan Subject: Re: Re: are the tufts gain are a per unit calculation? =if they are guaranteed. does it still trigger? what is the tax= on ubti. fo