Epstein Secrets

ion. I will bring the Estate Overview to our meeting with Leon on Wednesday so we can walk him through it. EFTA00663454 Best regards, Ada Clapp Black Family Partners do Apollo Management 9 W 57th Street IRS Circular 230 Disclosure: Pursuant to IRS regulations, I inform you that any tax advice contained in this

tly in effect. Items to highlight (noted with the last version): • The Overview illustrates the 1997 Trust and the 2006 Trust already decanted into the Heritage Trust. • BFP interests are discounted 30% to reflect the reality of the Note substitution. This deflates the value of Leon's estate (good for estate tax

changes by providing that the CLATs will be funded only in the event there is an estate tax upon Leon's death. Funding the CLATs with interests in Black Family Partners, L.P. ("BFP") has the potential to make the CLATs very successful in building value for the remainder beneficiaries as such interests are highly EF

the Black Family 1997 GST Exempt Trust holds GST tax- exempt assets. Because that trust does not include the more tailored governance provisions of the Heritage Trust, it may be desirable to consolidate the GST exempt assets in a single trust. 6 As of December 31, 2016. 7 In Part III.a. below, we recommend pou

dd Debra as a co-Trustee of the the APO1 and APO2 trusts after his death (she is only added as a Trustee of the Marital Trust, if any)? Ada Clapp Black Family Partners IRS Circular 230 Disclosure: Pursuant to IRS regulations, I inform you that any tax advice contained in this communication (including attachments)

please confirm October funding as opposed to November (with lower rate). Also, the Trustees listed in the APO I and APO2 trusts are the same as in the Heritage Trust: that is, Barry Cohen, John Hannan and Richard Ressler. Just want to confirm that this is what Leon wants (and not Paul Weiss's assumption when dra

Black Family Partners Apollo Management 9 West 57th Street New York, New York 10019 Ada Cla Phone: Email: To: Leon D. Black From: Ada Clapp Date: October 23, 2

ets of the Non-Exempt Trust under the Black Family 1997 Trust upon a decanting of such trust by its trustees. Once you have settled on the terms of the Heritage Trust, it will be the ultimate recipient of the assets held under this Agreement. I. Discretionary Trust. Until such time as the Trustees decide to crea