Epstein Secrets

rchasen Single_vs_Double_Lifeinterests.docx; ATT00001.htm Good morning. See attached. Sent from my iPad Begin forwarded message: From: "Halperin, Alan S" < Date: June 13, 2014 at 1:41:19 PM EDT To: "Ada Clapp Cc: "Hurtado, Christopher L" Subject: Split Interest Purchase I welcome your input. Than

nterest_Purchasen Single_vs_Double_Lifeinterests.docx; ATT00001.htm Good morning. See attached. Sent from my iPad Begin forwarded message: From: "Halperin, Alan S" < Date: June 13, 2014 at 1:41:19 PM EDT To: "Ada Clapp Cc: "Hurtado, Christopher L" Subject: Split Interest Purchase I welcome your inp

nue Code or (II) promoting, marketing or recommending to another party any transaction or matter addressed herein. Click Here for More Information Alan S. Halperin ( Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas New York NY 10019-6064 Direct Fax) www.paulweiss.com This mes

. See attached. Sent from my iPad Begin forwarded message: From: "Halperin, Alan S" < Date: June 13, 2014 at 1:41:19 PM EDT To: "Ada Clapp Cc: "Hurtado, Christopher L" Subject: Split Interest Purchase I welcome your input. Thanks. Alan IRS Circular 230 disclosure: To ensure compliance with requirements imposed

they used ? On Mon, Jun 23, 2014 at 8:04 AM, Ada Clapp < > wrote: Good morning. See attached. Sent from my iPad Begin forwarded message: From: "Halperin, Alan S" Date: June 13, 2014 at 1:41:19 PM EDT To: "Ada Clapp ( )" EFTA00721175 Cc: "Hurtado, Christopher L" < Subject: Split Interest Purchase

enue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. Click Hem for More Information Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 19-6064 (Direct Fax) www.paulweiss.com This message is intended only for the use of the A

? On Mon, Jun 23, 2014 at 8:04 AM, Ada Clapp < > wrote: Good morning. See attached. Sent from my iPad Begin forwarded message: From: "Halperin, Alan S" Date: June 13, 2014 at 1:41:19 PM EDT To: "Ada Clapp ( )" EFTA00721175 Cc: "Hurtado, Christopher L" < Subject: Split Interest Purchase I welc

ent from my iPad Begin forwarded message: From: "Halperin, Alan S" Date: June 13, 2014 at 1:41:19 PM EDT To: "Ada Clapp ( )" EFTA00721175 Cc: "Hurtado, Christopher L" < Subject: Split Interest Purchase I welcome your input. Thanks. Alan IRS Circular 230 disclosure: To ensure compliance with requirements impose

no definitive authority, there is a risk that, where a grantor trust is the lender, the grantor would be subject to income tax on imputed interest. Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019.6064 From: Halperin, Alan S [mailto Sent:

ntly unclear and has potential risk. Is a straight out distribution to Ben an option? Sent from my iPad Begin forwarded message: From: "Halperin, Alan S" Date: September 18, 2014 at 3:56:43 PM EDT To: Ada Clapp Cc: "Hurtado, Christopher L" Subject: RE: Quick Quesiton Hi Ada, I have dug deeper i

is apparently unclear and has potential risk. Is a straight out distribution to Ben an option? Sent from my iPad Begin forwarded message: From: "Halperin, Alan S" Date: September 18, 2014 at 3:56:43 PM EDT To: Ada Clapp Cc: "Hurtado, Christopher L" Subject: RE: Quick Quesiton Hi Ada, I have dug

n an option? Sent from my iPad Begin forwarded message: From: "Halperin, Alan S" Date: September 18, 2014 at 3:56:43 PM EDT To: Ada Clapp Cc: "Hurtado, Christopher L" Subject: RE: Quick Quesiton Hi Ada, I have dug deeper into your question and have found nothing directly on point. However, upon reflection, the

no definitive authority, there is a risk that, where a grantor trust is the lender, the grantor would be subject to income tax on imputed interest. Alan S. Halperin I Partner Paul, Weiss, Ftificind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019.6064 From: Halperin, Alan S [mailto: Se

ntly unclear and has potential risk. Is a straight out distribution to Ben an option? Sent from my iPad Begin forwarded message: From: "Halperin, Alan S" Date: September 18, 2014 at 3:56:43 PM EDT To: Ada Clapp Cc: "Hurtado, Christopher L" Subject: RE: Quick Quesiton Hi Ada, I have dug deeper in

is apparently unclear and has potential risk. Is a straight out distribution to Ben an option? Sent from my iPad Begin forwarded message: From: "Halperin, Alan S" Date: September 18, 2014 at 3:56:43 PM EDT To: Ada Clapp Cc: "Hurtado, Christopher L" Subject: RE: Quick Quesiton Hi Ada, I have dug d

en an option? Sent from my iPad Begin forwarded message: From: "Halperin, Alan S" Date: September 18, 2014 at 3:56:43 PM EDT To: Ada Clapp Cc: "Hurtado, Christopher L" Subject: RE: Quick Quesiton Hi Ada, I have dug deeper into your question and have found nothing directly on point. However, upon reflection, the

is apparently unclear and has potential risk. Is a straight out distribution to Ben an option? Sent from my iPad Begin forwarded message: From: "Halperin, Alan S" < Date: September 18, 2014 at 3:56:43 PM EDT To: Ada Clapp < Cc: "Hurtado, Christopher L" Subject: RE: Quick Quesiton Hi Ada, I have d

y view that, so long as the loan is made to a beneficiary, there is no income tax consequence of an interest-free loan. Chris, can you investigate? Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019-6064 (212) 373-3313 (Direct Phone) 1 (212)

n option? Sent from my iPad Begin forwarded message: From: "Halperin, Alan S" < Date: September 18, 2014 at 3:56:43 PM EDT To: Ada Clapp < Cc: "Hurtado, Christopher L" Subject: RE: Quick Quesiton Hi Ada, I have dug deeper into your question and have found nothing directly on point. However, upon reflection, ther