Epstein Secrets

ided won't work for complex reasons. Joe, John and Rich should feel free to supplement my outline. Barry J. Cohen I President and Special Counsel Elysium Management, LLC 445 Park Avenue Suite 1401 New York, NY 10022 I please note The information contained in this communication is confidential, may be attorne

the following approach to deducting advisor fees that involved setting up and structuring (construed fairly broadly) a new disregarded entity, like AP Narrows, and others. 1. Find entities which were set up a. within the last 2 years, and b. the advisor expenses were incurred prior to an entity's starti

ership). Bad fact to be sure but perhaps Alan knows of other cases where sales were not respected and 2036 applied. Ada Clapp Chief Legal Officer Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022 This communication and any attachment is for the intended recipient(s) only and may contain i

ed the point that there is a "bona fide sale" exception to Section 2036 and asked whether we still need to restrict Leon's powers as a Class A GP of AP Narrows if in the future he sells, rather than gifts, his LP interest in AP Narrows. Your point, as I understand it, is that Leon could have all the power o

s to be a disregarded e=tity for income tax purposes or taxed as a partnership, so I just wanted t= flag this to you. Best, Heather Heather Gray Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022 Direct Dial: Fax: Email: 1 EFTA_R1_01399156 EFTA02382934

o if the trusts purchase the Dante and then contribute their interests in the Dante to AP =arrows LP in exchange for limited partnership interests, AP Narrows will b= treated as a partnership for income tax purposes (not a pass-through enti=y). I'm not sure where you and Leon came out on th= question of wh

s to be a disregarded=entity for income tax purposes or taxed as a partnership, so I just wanted=to flag this to you. Best, Heather Heather Gray Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022 Direct Dial: Fax: Email: • <tel <tel <mailto <1=> 1 EFTA_R1_01630954 EFTA02502587

ership for income tax purposes (not a pass-through enti=y). I'm not sure where you and Leon came out on =he question of whether you would prefer for AP Narrows to be a disregarded=entity for income tax purposes or taxed as a partnership, so I just wanted=to flag this to you. Best, Heather Heather Gray E

e=ica loan) I'll send you another email with the rest of t=e (smaller) purchases, but wanted to get this to you ASAP. Best, Heather Heather Gray Elysium Management LLC 445 Park Avenue 2 EFTA_R1_01368383 EFTA02368942 Suite 1401 New York, New York 10022 Direct Dial: Fax: Email: 3 EFTA_R1_01368384 EFTA0236

Subject: FW: recent art purchases Question to JEE so as =o clarify 1)&n=sp; Going forward =#8211; which entity should be purchaser fo fine art: AP Narrows or N=rrows LLC? (You noted Narrows but want to make sure which Narrows en=ity) 2)&n=sp; There has been=instruction to transfer recent acquisitions

initial funding of AP Narrows. =Brad and I will give you a call on Monday for your comments. Have a nice weekend! Ada Clapp Chief Legal Officer Elysium Management LLC 445 Park Avenue Suite 1401 New York, New York 10022 Direct Dial: Fax: Email: c=pan style="color:#0563C1 This communication and any attachment

ws Timeline (5.15.15).pdf Hi Jeffrey, Attached is the timeline Brad asked me to put togeth=r listing the steps leading up to the initial funding of AP Narrows. =Brad and I will give you a call on Monday for your comments. Have a nice weekend! Ada Clapp Chief Legal Officer Elysium Management LLC 445 Pa