Epstein Secrets

m GRATs. And we also may want to explore techniques to get a stepped up b=sis. And finally, we might want to re-visit the freeze partnership idea. Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison =LP 1285 Avenue of the Americas I New York NY 10019-6064 From: jeffrey E. Sent: Sunday, Septe

l.com> Sent: Sunday, September 20, 2015 12:19 PM To: Halperin, Alan Subject: Re: could you call me On Sun, Sep 20, 2015 at 8:13 AM, Ha=perin, Alan S < wrote: Hi Jeff. As you know, we must consider these questions in the context of ot=er facts, such as: > > 1. The grantor does not have other as

From: jeffrey E. <[email protected]> Sent: Sunday, September 20, 2015 12:19 PM To: Halperin, Alan Subject: Re: could you call me On Sun, Sep 20, 2015 at 8:13 AM, Ha=perin, Alan S < wrote: Hi Jeff. As you know, we must consider these qu

available to use=as currency to buy the GRAT assets at today's value (and then start ov=r); 2. The grantor already has ensured the success of early GRATS (created by C=rlyn) via purchase; 3. We still need to address the $1.6 b note; 4.=The GRAT rules prohibit commutation and a purchase of the GRAT ass

be finalized shortly) From: Richard Joslin Sent: Wednesday, February 11, 2015 12:22 PM To: 'Hurtado, Christopher L' Cc: Thomas Turrin; Halperin, Alan S; tax Subject: 2014 Gifts to GRATs (Alan's calculations) Chris: Please calculate ESTIMATED gift amounts for the 4 GRATS funded in 2014. Please see

ounts will be finalized shortly) From: Richard Joslin Sent: Wednesday, February 11, 2015 12:22 PM To: 'Hurtado, Christopher L' Cc: Thomas Turrin; Halperin, Alan S; tax Subject: 2014 Gifts to GRATs (Alan's calculations) Chris: Please calculate ESTIMATED gift amounts for the 4 GRATS funded in 2014. Ple

: Thomas Turrin; Halperin, Alan S; tax Subject: 2014 Gifts to GRATs (Alan's calculations) Chris: Please calculate ESTIMATED gift amounts for the 4 GRATS funded in 2014. Please see attached. Please send your calculations to Tom Turrin as well as myself. As soon as I have the finalized valuations, I w

l captain's license. From: Thomas Turri Sent: Tuesday, May 10, 2016 10:48 AM To: Jeffrey E. <[email protected] <mailto:[email protected]»; Halperin, Alan S Subject: GIFT TAX AUDIT Alan and Jeffrey, The agent finally called me this morning. He was apologetic that he didn't call sooner. He sai

s license. From: Thomas Turri Sent: Tuesday, May 10, 2016 10:48 AM To: Jeffrey E. <[email protected] <mailto:[email protected]»; Halperin, Alan S Subject: GIFT TAX AUDIT Alan and Jeffrey, The agent finally called me this morning. He was apologetic that he didn't call sooner. He said he=E2

or more time. The bad news is that they will also examine 2014. He told me a letter will go out soon. Mr. Falk readily volunteered that it is the GRATS (s=ecifically the valuations) that are kicking off the audits. He did say that he would try to "move the au=its alone.... He also said he sees (and

, 175 owed. From: Thomas Turrin [mailto Sent: Tuesday, May 10, 2016 10:48 AM To: 'effre E. .c'eevacation@ mail.com <mailto:[email protected]»; Halperin, Alan < =» Subject: GIFT TAX AUDIT EFTA_R1_01871029 EFTA02638966 Alan and Jeffrey, The agent finally called me this morning. 40 He was apolo

or more time. The bad news is that they will also examine 2014.4 He told me a letter will go out soon. Mr. Falk readily volunteered that it is the GRATS (s=ecifically the valuations) that are kicking off the audits. He did say that he would try to "move the au=its alone.... He also said he sees (and

From: Thomas Turrin Sent: Tuesday, May 10, 2016 2:48 PM To: jeffrey E.; Alan S. Halperin Subject: GIFT TAX AUDIT Alan and Jeffrey, The agent finally called me this morning. = He was apologetic that he didn't call sooner. He said he=;s

ore time. The bad news is that they will also examine 2014.&nb=p; He told me a letter will go out soon. Mr. Falk readily volunteered that it is the GRATS (s=ecifically the valuations) that are kicking off the audits. He did say that he would try to "move the audi=s along".... He also said he sees (and

From: Halperin, Alan S == Sent: Tuesday, May 10, 2016 4:11 PM To: Thomas Turrin; jeffrey E. Subject: RE: GIFT TAX AUDIT Thanks. I am working o= a proposed re

02702930 The bad news is that they will also examine 2014.&nb=p; He told me a letter will go out soon. Mr. Falk readily volunteered that it is the GRATS (s=ecifically the valuations) that are kicking off the audits. He did say that he would try to "move the audi=s along".... He also said he sees (and

From: Thomas Turrin Sent: Tuesday, May 10, 2016 4:34 PM To: Halperin, Alan 5; Jeffrey E. Subject: RE: GIFT TAX AUDIT Attachments: Bryant Grp - 2013 Split Dollar Life Insurance.pdf The password is my off=ce zip cod

ore time. The bad news is that they will also examine 2014.&nb=p; He told me a letter will go out soon. Mr. Falk readily volunteered that it is the GRATS (s=ecifically the valuations) that are kicking off the audits. He did say that he would try to "move the audi=s along".... He also said he sees (and

om</=» <mailt Date: Tue, May 10, 2016 at 10:48 AM Subject: GIFT TAX A=DIT To: "jeffrey E." <[email protected] <mailto:jeevacation@gmail.=om», "Alan S. Halperin" Alan and Jeffrey, The agent finally called me this morning. l> He was apologetic that he didn't call sooner. He said he=E2404>s been in and out

r more time. The bad news is that they will also examine 2014.40 He told me a letter will go out soon. Mr. Falk readily volunteered that it is the GRATS (s=ecifically the valuations) that are kicking off the audits. He did say that he would try to "move the au=its along".... He also said he sees (and