Epstein Secrets

recommending to another party any transaction or matter addressed herein. Click Hem for More Information Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 19-6064 (Direct Fax) www.paulweiss.com This message is intended only for the use of the Addressee and may contain informa

ent from my iPad Begin forwarded message: From: "Halperin, Alan S" Date: June 13, 2014 at 1:41:19 PM EDT To: "Ada Clapp ( )" EFTA00721175 Cc: "Hurtado, Christopher L" < Subject: Split Interest Purchase I welcome your input. Thanks. Alan IRS Circular 230 disclosure: To ensure compliance with requirements impose

recommending to another party any transaction or matter addressed herein. Click Here for More Information Alan S. Halperin ( Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas New York NY 10019-6064 Direct Fax) www.paulweiss.com This message is intended only for the us

. See attached. Sent from my iPad Begin forwarded message: From: "Halperin, Alan S" < Date: June 13, 2014 at 1:41:19 PM EDT To: "Ada Clapp Cc: "Hurtado, Christopher L" Subject: Split Interest Purchase I welcome your input. Thanks. Alan IRS Circular 230 disclosure: To ensure compliance with requirements imposed

that, where a grantor trust is the lender, the grantor would be subject to income tax on imputed interest. Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019.6064 From: Halperin, Alan S [mailto Sent: Wednesday, September 17, 2014 5

n an option? Sent from my iPad Begin forwarded message: From: "Halperin, Alan S" Date: September 18, 2014 at 3:56:43 PM EDT To: Ada Clapp Cc: "Hurtado, Christopher L" Subject: RE: Quick Quesiton Hi Ada, I have dug deeper into your question and have found nothing directly on point. However, upon reflection, the

to a beneficiary, there is no income tax consequence of an interest-free loan. Chris, can you investigate? Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP EFTA00869483 1285 Avenue of the Americas New York NY 10019-6064 From: Ada aapp [mailto: Sent: Wednesday, September 17, 2

en an option? Sent from my iPad Begin forwarded message: From: "Halperin, Alan S" Date: September 18, 2014 at 3:56:43 PM EDT To: Ada Clapp Cc: "Hurtado, Christopher L" Subject: RE: Quick Quesiton Hi Ada, I have dug deeper into your question and have found nothing directly on point. However, upon reflection, the

rantor trust is the lender, the grantor would be subject to income tax on imputed interest. EFTA00678131 Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019-6064 (212) 373-3313 (Direct Phone) 1 (212) 492-0313 (Direct Fax) From: Ha

n option? Sent from my iPad Begin forwarded message: From: "Halperin, Alan S" < Date: September 18, 2014 at 3:56:43 PM EDT To: Ada Clapp < Cc: "Hurtado, Christopher L" Subject: RE: Quick Quesiton Hi Ada, I have dug deeper into your question and have found nothing directly on point. However, upon reflection, ther