Epstein Secrets

ote: via home staff a letter from IRS denying to respond to inquity from PW finduciary attorney. Details as to the inquiry follow. From: Halperin, Alan S [mailto Sent: Tuesday, September 30, 2014 11:33 AM To: Richard Joslin; Hurtado, Christopher L Subject: RE: question I understand. Chris, on this

slin • wrote: via home staff a letter from IRS denying to respond to inquity from PW finduciary attorney. Details as to the inquiry follow. From: Halperin, Alan S [mailto Sent: Tuesday, September 30, 2014 11:33 AM To: Richard Joslin; Hurtado, Christopher L Subject: RE: question I understand. Chris,

understand. Chris, on this project, is there anything else to be done on our end? Going forward, we will handle as you have directed. Thanks. Alan Alan S. Halperin I Partner Paul, Weiss, Ftifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019-6064 From: Richard Joslin [mailto: Sent:

ttorney. Details as to the inquiry follow. From: Halperin, Alan S [mailto Sent: Tuesday, September 30, 2014 11:33 AM To: Richard Joslin; Hurtado, Christopher L Subject: RE: question I understand. Chris, on this project, is there anything else to be done on our end? Going forward, we will handle as you hav

> Subject: FW: question Date: Tue, 30 Sep 2014 18:14:36 +0000 From: Hurtado, Christopher L [mailto Sent: Tuesday, September 30, 2014 1:50 PM To: Halperin, Alan S; Richard Joslin Subject: RE: question Rich, An additional EIN was not requested on September 18th. The inquiry was to confirm that the IRS

understand. Chris, on this project, is there anything else to be done on our end? Going forward, we will handle as you have directed. Thanks. Alan Alan S. Halperin I Partner Paul, Weiss, Rif kind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019-6064 From: Richard Joslin mailto Sent: T

: FW: question Date: Tue, 30 Sep 2014 18:14:36 +0000 From: Hurtado, Christopher L [mailto Sent: Tuesday, September 30, 2014 1:50 PM To: Halperin, Alan S; Richard Joslin Subject: RE: question Rich, An additional EIN was not requested on September 18th. The inquiry was to confirm that the IRS had the

From: Richard Joslin To: jeffrey E. <[email protected]> Subject: FW: question Date: Tue, 30 Sep 2014 18:14:36 +0000 From: Hurtado, Christopher L [mailto Sent: Tuesday, September 30, 2014 1:50 PM To: Halperin, Alan S; Richard Joslin Subject: RE: question Rich, An additional EIN was not req

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

e of the Americas I New York, NY 10019.6064 From: Halperin, Alan S [mailto Sent: Wednesday, September 17, 2014 5:27 PM To: Ada Clapp Cc: Hurtado, Christopher L Subject: Re: Quick Quesiton Interesting. It has been my view that, so long as the loan is made to a beneficiary, there is no income tax consequenc

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

of the Americas I New York, NY 10019.6064 From: Halperin, Alan S [mailto: Sent: Wednesday, September 17, 2014 5:27 PM To: Ada Clapp Cc: Hurtado, Christopher L Subject: Re: Quick Quesiton Interesting. It has been my view that, so long as the loan is made to a beneficiary, there is no income tax consequenc

u have received them in error. Thank you. From: Hurtado, Christopher L [mailto Sent: Wednesday, June 25, 2014 3:57 PM To: Ada Clapp Cc: Halperin, Alan S Subject: RE: Summary of open Will/Heritage Trust items E FTA_R1_02204236 EFTA02720696 Hi Ada, On behalf of Alan, I am forwarding the summary of

ly that you have received them in error. Thank you. From: Hurtado, Christopher L [mailto Sent: Wednesday, June 25, 2014 3:57 PM To: Ada Clapp Cc: Halperin, Alan S Subject: RE: Summary of open Will/Heritage Trust items E FTA_R1_02204236 EFTA02720696 Hi Ada, On behalf of Alan, I am forwarding the su

eduction rules concerning fractional gifts under 170(o)). We will put those other projects aside and focus on the list of open items. Thanks. Alan Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I Ncw York, NY 10019-6064 Direct Phone) I..= (Direct Fax) w

lete all copies of this communication and its attachments and notify me immediately that you have received them in error. Thank you. From: Hurtado, Christopher L [mailto Sent: Wednesday, June 25, 2014 3:57 PM To: Ada Clapp Cc: Halperin, Alan S Subject: RE: Summary of open Will/Heritage Trust items E FTA_R

, Christopher L [mailto: Sent: Tuesday, September 02, 2014 11:01 AM To: Eileen Alexanderson; Richard Joslin; Heather Gray Cc: Ada Clapp; Halperin, Alan S Subject: GRAT Annuity Payments and new GRAT Agreement Eileen, Rich and Heather, In connection with the upcoming GRAT annuity payments and the new

m: Hurtado, Christopher L [mailto: Sent: Tuesday, September 02, 2014 11:01 AM To: Eileen Alexanderson; Richard Joslin; Heather Gray Cc: Ada Clapp; Halperin, Alan S Subject: GRAT Annuity Payments and new GRAT Agreement Eileen, Rich and Heather, In connection with the upcoming GRAT annuity payments and

lete all copies of this communication and its attachments and notify me immediately that you have received them in error. Thank you. From: Hurtado, Christopher L [mailto: Sent: Tuesday, September 02, 2014 11:01 AM To: Eileen Alexanderson; Richard Joslin; Heather Gray Cc: Ada Clapp; Halperin, Alan S Subject

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)

Direct Phone) 1 (212) 492-0313 (Direct Fax) From: Halperin, Alan S [mailto Sent: Wednesday, September 17, 2014 5:27 PM To: Ada Clapp Cc: Hurtado, Christopher L Subject: Re: Quick Quesiton Interesting. It has been my view that, so long as the loan is made to a beneficiary, there is no income tax consequence

understand. Chris, on this project, is there anything else to be done on our end? Going forward, we will handle as you have directed. Thanks. Alan Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas l New York, NY 10019-6064 [email protected] <javascript:_

wrote: I rec'd via home staff a letter from IRS denying to respond to inquity from PW finduciary attorney. Details as to the inquiry follow. From: Halperin, Alan S <javascript:_e(%7B%7D;cvmr;[email protected].);> Sent: Tuesday, September 30, 2014 11:33 AM To: Richard Joslin; Hurtado, Christopher

m: Halperin, Alan S <javascript:_e(%7B%7D;cvmr;[email protected].);> Sent: Tuesday, September 30, 2014 11:33 AM To: Richard Joslin; Hurtado, Christopher L Subject: RE: question I understand. Chris, on this project, is there anything else to be done on our end? Going forward, we will handle as you hav

for your input.=o:p> -Ada From: Hurtado, Christopher L [mailto Sent: Tuesday, October 21, 2014 1:02 PM To: Ada Clapp; Heather Gray Cc: Halperin, Alan S Subject: Licensing Agreement Ada and Heather,<=o:p> We are working o= a licensing agreement for use of the Phaidon name by Narrows Holdings LLC= W

? Thanks for your input.=o:p> -Ada From: Hurtado, Christopher L [mailto Sent: Tuesday, October 21, 2014 1:02 PM To: Ada Clapp; Heather Gray Cc: Halperin, Alan S Subject: Licensing Agreement Ada and Heather,<=o:p> We are working o= a licensing agreement for use of the Phaidon name by Narrows Holding

Will the new art entity be paying Phaidon f=r the license? How do we determine the licensing fee? Thanks for your input.=o:p> -Ada From: Hurtado, Christopher L [mailto Sent: Tuesday, October 21, 2014 1:02 PM To: Ada Clapp; Heather Gray Cc: Halperin, Alan S Subject: Licensing Agreement Ada and Heather,<=

ho=e staff a letter from IRS denying to respond to inquiry from PW finduciary=attorney. Details as to the inquiry follow. </=pan> From: Halperin, Alan S [mailto Sent: Tuesday, September 30, 2014 11:33 AM To: Richard Joslin; Hurtado, Christopher L Subject: RE: question I understand. Chris, o= this

rec'd via ho=e staff a letter from IRS denying to respond to inquiry from PW finduciary=attorney. Details as to the inquiry follow. </=pan> From: Halperin, Alan S [mailto Sent: Tuesday, September 30, 2014 11:33 AM To: Richard Joslin; Hurtado, Christopher L Subject: RE: question I understand. Chris,

Details as to the inquiry follow. </=pan> From: Halperin, Alan S [mailto Sent: Tuesday, September 30, 2014 11:33 AM To: Richard Joslin; Hurtado, Christopher L Subject: RE: question I understand. Chris, o= this project, is there anything else to be done on our end? G=ing forward, we will handle as you hav