Epstein Secrets

lender is not making any transfer, as is the case in your most recent email. Again, Rick may have a view. Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019-6064 > I www.paulweiss.com<http://www.paulweiss.com> From: Jeffrey E. [ma

ator would be the number of days held by the charity and the denominator would be 365. But we would need to investigate further. Under current TRA, Tufts gain gives rise to TRA rights only if the gain is triggered in connection with an exchange. Here, the Tufts gain would be triggered by the contribut

h the public company). =ote that the donor advised fund may not accept property which generates UBTI. </=> Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison LIP I New York, NY 10019-6064 (=irect Phone) I (=irect Fax) www.paulweiss.com <http:/ www.paulweiss.com> 2 EFTA_R1_0157956

ator would be the number of days held by the charity and the denominator would =e 365. But we would need to investigate further. Under current TRA, Tufts gain gives r=se to TRA rights only if the gain is triggered in connection with an excha=ge. Here, the Tufts gain would be triggered by the contribut

es, then there may be other reporting requirements (such as under S=ction 13(d) of the Exchange Act). Alan Alan S. Halperin I Partner Paul Weiss, Rifkind, Wharton & Garrison LLP New York, NY 10019-6064 3 EFTA_R1_01579561 EFTA02469239

othing inherit in the laws that govern donor advised fund= which would prohibit such a contribution. However, such a contribution wo=ld trigger the Tufts gain. Further, the donor advised fund would have taxable income, as the AOG units will gi=e rise to UBTI. Under the current TRA, the Tufts gain, unl