Epstein Secrets

e applicable and separate form (Form CT61) would need to be submitted to HMRC until treaty clearance is obtained. There would be the capability for Phaidon to apply for a refund of any withholding tax suffered pre-treaty clearance. Double Taxation Treaty Passport Scheme An alternative approach is apply

the passport. The lender will be listed in HRMC public database. No IRS certification of US status is needed. Note I indirectly reached out to BDO (Phaidon tax and accounting firm) and they provided some explanation below. The author has never undertaken either the claim or passport procedures. Note tha

[email protected]> Subject: FW: question on interest Date: Wed, 25 Mar 2015 19:42:23 +0000 Let's discuss at 4:45 (if there is time) Re Interest paid by Phaidon Press (UK) to Phaidon Global (US) As you know, the payment of interest by a UK person to a non-UK person may give rise to UK income tax withholding of 20

out to the Trustees to inquire abo=t retaining counsel. I can also reach out to Keith to let him know we wil= be sending him the loan documents for Phaidon's review. Please let me know how you wish to proceed. Thanks. Ada Clapp Chief Legal Officer EFTA_R1_01781867 EFTA02596656 Elysium Management L

as borrower= With a new management team in place, I think it makes sense for Keith or=Phaidon Global's general counsel to negotiate loan terms for Phaidon (part=cularly since the borrowed funds will be used to benefit Phaidon Press and=Artspace, which are part of Keith's business plan). I assume Rich J

nse for Keith or=Phaidon Global's general counsel to negotiate loan terms for Phaidon (part=cularly since the borrowed funds will be used to benefit Phaidon Press and=Artspace, which are part of Keith's business plan). I assume Rich J. is =iscussing profitability projections and required loan amount with Keith

m: Jeffrey Epstein [mailto:[email protected]] Sent: Friday, April 12, 2013 06:39 PM Eastern Standard Time To: Eileen Alexanderson Subject: Re: Phaidon sub-part f is not a problem at all, i would like to see how tom showed this investment, what is the interest rate and terms of top mid debt. . i wo

end. The one issue I believe you will need to consider if Phaidon was to purchase are relates to the US tax aspects of subpart F income and whether Phaidon owning art (or eventually selling it at a gain) would create that type of income. I believe it might. As I mentioned this morn, I have a call on Mo

interest deductibility purposes and be converted to equity if we choose. Great care was taken to avoid creating phantom income. Profit or loss at Phaidon Press level has no impact for us until we choose to issue a dividend. The one issue I believe you will need to consider if Phaidon was to purchase are rel

3.2MM leaving Bidco and dropping down to Phaidon Press for the acquisition of the preferred shares, that money moved from Bidco's US bank account to Phaidon's UK bank account. The second $1.6MM wire was authorized by an email from Eileen; likely same result for first $1.6MM, but not nailed down yet. Th

UK auditors this morning and went through the steps to quickly to clean-up this mess. With respect to the $3.2MM leaving Bidco and dropping down to Phaidon Press for the acquisition of the preferred shares, that money moved from Bidco's US bank account to Phaidon's UK bank account. The second $1.6MM wire was

Buy Artspace Date: Thu, 14 Aug 2014 14:48:02 +0000 Always and in this case specifically we are referring to Artspace being acquired and owned by a 'Phaidon affiliated' company From: Jeffrey E. [mailto:[email protected]] Sent: Thursday, August 14, 2014 10:46 AM To: Eileen Alexanderson; Melanie Spi

From: Eileen Alexanderson To: jeffrey E. <[email protected]> Subject: RE: Bloomberg: Billionaire Leon Black's Phaidon Press in Talks to Buy Artspace Date: Thu, 14 Aug 2014 14:48:02 +0000 Always and in this case specifically we are referring to Artspace being acquired and

016 budget for Phaidon Press as well as a very top line summary of Regan Arts. I have not included ArtSpace since I don't have a digestible summary. Phaidon is fairly complete so I hope this gives you what you generally need. Best. Brad please note The information contained in this communication is c

16 ? i can't follow On Thu, Jul 23, 2015 at 2:13 PM, Brad Wechsler < > wrote: Attached please find the 2015 performance review and 2016 budget for Phaidon Press as well as a very top line summary of Regan Arts. I have not included ArtSpace since I don't have a digestible summary. Phaidon is fairly complete

From: Richard Joslin Sent: Wednesday, April 1, 2015 11A0 AM To: Jeffrey E.; Brad Wechsler Subject: UK Phaidon Global's debt with Phaidon will be registered with UK HRMC passport=such that all debt is availed for zero treaty withholding prospectively. =or interest paid heretofore, 20%

eeks. Once passport is received, no withholdi=g. Since Phaidon Global was paid interest sans withholding, PhaidonGlobal=will have a small payable to Phaidon Press. Phaidon Global can make adjus=ment to grid note or just wire the S$ to Phaidon Press. <?xml version=.0" encoding=TF-8"?> <!DOCTYPE plist PUBLIC "

MM leaving Bidco and dropping down to Phaidon Press f=r the acquisition of the preferred shares, that money moved from BidcoR=7;s US bank account to Phaidon's UK bank account. The second $1.6MM wire was authorized by an email from Eileen; li=ely same result for first $1.6MM, but not nailed down yet. Th=

UK auditors this morning and went =hrough the steps to quickly to clean-up this mess. Wi=h respect to the $3.2MM leaving Bidco and dropping down to Phaidon Press f=r the acquisition of the preferred shares, that money moved from BidcoR=7;s US bank account to Phaidon's UK bank account. The second $1.6MM wire

Clapp <I To: Jeffrey E. <I CC: Brad Wechsler <I Subject: RE: Intra Family Notes - Offset Date: Mon, 09 Nov 2015 21:23:38 +0000 Hi Jeffrey, The Phaidon numbers on the schedule I sent you are not correct. That schedule is updated monthly by Samantha and she was not told that Global previously repaid

d monthly by Samantha and she was not told that Global previously repaid the $7.3 MM to BFP. I have asked her to confirm all the Phaidon Global and Phaidon Press loans with Rich J. We will send you an updated schedule with those details shortly. I apologize for the confusion. Ada Clapp Chief Legal Officer

Sent: Friday, April 12, 201311 To: Jeffrey Epstein ([email protected]) Subject: Phaidon Attachments: imq-412173234-0001.pdf Jeffrey, See Phaidon org structure attached. Mechanics of the purchase were as follows: PLB LLC was funded with $54mi1 from the Black Family 1997 Trust, $3mi1 from=the

K interest deductibility purposes and be =onverted to equity if we choose. Great care was taken to avoid creating ph=ntom income. Profit or loss at Phaidon Press level has no impact for us until we choose =o issue a dividend. The one issue I believe you will need to consider if P=aidon was to purchase are rel