Epstein Secrets

AGSH&F DISCUSSION DRAFT JUNE 19, 2013 Jeffrey, Here is a proposal for dealing with the negative capital accounts that the Principals have in their limited partnership interests in AMH (through

l income tax purposes (should be distinguishable from the preferred equity that was reviewed and held to be debt for federal income tax purposes in Castle Harbor . 3 104773603 v10 EFTA00582849

AGSH&F DISCUSSION DRAFT MAY 31, 2013 Jeffrey, Here is a strawman candidate for potentially dealing with the negative basis that the 3 principals have in their limited partnership interest in A

fectively subject to estate tax. 7. Impact on the tax effects if the preferred interests were treated as debt for federal income tax purposes (ala Castle Harbor decision). 8. Would the tax effects on basis/step up at death/estate tax considerations/non-tax considerations be the same if the SPV/principals ac

AGSH&F DISCUSSION DRAFT JUNE 19. 2013 Jeffrey, Here is a strawman-eandidateproposal for potentially-dealing with the negative basiscaoital Accounts that the 3--prineipalsPrincipals have in thei

al income tax purposes (should be distinguishable from thepreferred equity that was reviewed and held to be debt for federal income tax purposes in Castle Harbor 3 104773603 14.1,0 EFTA_R1_00451004 EFTA01969638 AGSH&F DISCUSSION DRAFT JUNE 19.2013 Calculation of thc value of thc preferred interests hel