Epstein Secrets

Key remaining LB open items: 1) final decision on deferring tax on form 8621 (PFIC income) 2) any deduction (and type) to be taken on lEE fees (and Elysium) Alan J. Dlugash Marks Paneth & Shron LLP 685 Third Avenue, New York, NY, 10017 P. I F. C. E. ;;Marks, Paneth & Shron Any tax advice in thi

ing LB open items: 1) final decision on deferring tax on form 8621 (PFIC income) 2) any deduction (and type) to be taken on lEE fees (and Elysium) Alan J. Dlugash Marks Paneth & Shron LLP 685 Third Avenue, New York, NY, 10017 P. I F. C. E. ;;Marks, Paneth & Shron Any tax advice in this e-mail should be

5 10:08 AM To: Dlugash, Alan Subject: Re: FW: elysum On Mon, Oct 5, 2015 at 6:52 PM, Dlugash, Alan wrote: Any reason that I shou=dn't suggest Elysium on the simple grounds that Elysium is where w= would prefer that any correspondence go? </=pan> ALAN J. DLUGASH, CPA=b> =u> Marks Paneth LIP 76

E. <[email protected]> Sent: Tuesday, October 6, 2015 10:08 AM To: Dlugash, Alan Subject: Re: FW: elysum On Mon, Oct 5, 2015 at 6:52 PM, Dlugash, Alan wrote: Any reason that I shou=dn't suggest Elysium on the simple grounds that Elysium is where w= would prefer that any correspondence go?

ousehold entities that also do not have Leon name I mention=d if sensitivity was true concern then they must make sure that address doe= not mention Elysium so it can be easily tied back to Leon </=iv> If public disclosure is not an issue Leon has enough cash in his pe=sonal account. Nothing was decid

pay fees <=>15,000,000 - 20,000,000 to STC B=ack Family Partners (BFP) was the preferred entity as it has many investmen=s other than BRH Holdings. Dlugash said at BFP level he thought we co=ld obtain an ordinary deduction There was also discussion that a =onion could be made from an Art Entity (I assu

=usehold entities that also do not have Leon name I mentioned if =ensitivity was true concern then they must make sure that address does not=mention Elysium so it can be easily tied back to Leon =div>lf public disclosure is not an issue Leon has enough cash in his perso=al account. Nothing was decided

to pay fees 15,000,000- 20,0=0,000 to STC Black Family Partners (BFP) =as the preferred entity as it has many investments other than BRH Holdings= Dlugash said at BFP level he thought we could obtain an ordinary de=uction There was also discussion that a portion could be made fr=m an Art Entity (I assu