Epstein Secrets

ate a new S-Corp the stock of which will be sold to the APO1 Trust. As long as it is a grantor trust, APO1 is eligible to hold Sub S Stock. However, Alan and I think we should make a protective Sub S election just in case an unexpected event should cause grantor trust status to cease. Paul Weiss tells

John Castrucci Subject: S-Corp Election Hi Rich, As part of the year-end planning, we will create a new S-Corp the stock of which will be sold to the APO1 Trust. As long as it is a grantor trust, APO1 is eligible to hold Sub S Stock. However, Alan and I think we should make a protective Sub S election just

ate a new S-Corp the stock of which will be sold to the APO1 Trust. As long as it is a grantor trust, APO1 is eligible to hold Sub S Stock. However, Alan and I think we should make a protective Sub S election just in case an unexpected event should cause grantor trust status to cease. Paul Weiss tells

John Castrucci Subject: S-Corp Election Hi Rich, As part of the year-end planning, we will create a new S-Corp the stock of which will be sold to the APO1 Trust. As long as it is a grantor trust, APO1 is eligible to hold Sub S Stock. However, Alan and I think we should make a protective Sub S election just

Outline of Proposals Forwarded me=sage From: Alan S Halperin= ailto Date: Thu, Jan 23, 2014.1111

to NewCo (if trapping income on the note payments, to avoid mandatory payments to children, is desired). e. The 2011 LLC and Debra (a beneficiary of the APO1 Trust) will then enter into an art use agreement, without any rent. We should consider who is to pay insurance on such art. 4. The desired consequences i

From: Alan S Halperin < Sent: Thursday, January 23, 2014 1

to NewCo (if trapping income on the note payments, to avoid mandatory payments to children, is desired). e. The 2011 LLC and Debra (a beneficiary of the APO1 Trust) will then enter into an art use agreement, without any rent. We should consider who is to pay insurance on such art. 4. The desired consequences i