From: Heather Gray To: "Jeffrey Epstein ([email protected])" <[email protected]> Subject: FW: sales tax Date: Thu, 30 Apr 2015 22:33:10 +0000 Hi Jeffrey, Paul Weiss agrees that the trade-in credit applies to art. This is the tax partner that Alan had weigh in: http://www.paulweiss.com/professionals partners-and-counselirichard-j-bronstein.aspx. Best, Heather From: Halperin, Alan S [mailto Sent: Thursday, April 30, 2015 6:29 PM To: Heather Gray Cc: Ada Clapp; Bronstein, Richard.' Subject: RE: sales tax We agree. Thanks. Alan Alan S. Halperin I Partner Paul, Weiss, Rif kind, Wharton & Garrison LLP I New York, NY 10019-6064 (Direct Phone) (Direct Fax) From: Heather Gray [mailto: Sent: Thursday, April 30, 2015 5:54 PM To: Halperin, Alan Cc: Ada Clapp Subject: sales tax Hi Alan, So nice speaking with you earlier today, and I hope you feel better soon) As I mentioned on our call, I wanted to check in with your sales tax people as to whether they think the trade-in credit provided under NY Sales and Use Tax Regulations section 526.5(f) applies to a trade-in of art to an art dealer. (For the record, I believe that it does.) The scenario we are imagining is as follows: Collector wants to buy Artwork A from Gallery for $100. Gallery is a NYC art gallery that is in the business of buying and selling works of art. Collector and Gallery agree that Collector will trade in Artwork B in part payment for Artwork A. Gallery gives Collector credit for $75 (the value of Artwork B) and charges Collector $25 cash plus NY sales tax on $25. Gallery intends to sell Artwork B to a different client. Thanks, Heather Heather Gray EFTA00857993

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