From: Halperin, Alan 5== Sent: Saturday, September 26, 2015 3:16 PM To: Jeffrey E. Subject: Re: I was not available earlier. I am available now (11:15), 4 and tomorrow mor=ing. Alan Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison =LP 1285 Avenue of the Americas I = •NY 10019- (Direct Phone) Direct Fax I www.paulweiss.com From: Jeffrey E. Sent: Saturday, September 26, 2015 7:38 AM To: Halperin, Alan Subject: Re: On Sat, Sep 26, 2015 at 6:51 AM, Halperin, Alan = wrote: mailtoa The annuity payment must be paid within the specified window (that is withi= 105 days of the anniversary date or calendar year). There is no express a=thority of how to apply this rule (providing administrative convenience) w=en the annuity is payable multiple times a year. <te Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison =LP the Americas New York &=bs •NY 10019-6064 .ct Direct Phone) I (Dire mailto I www.paulweiss.com <http://www.paulweiss.com> From: jeffrey E. Sent: Saturday, September 26, 2015 6:45 AM To: Halperin, Alan S Subject: Re: why is not semi annual payments with the last paymen= on the anniversary date qualify, it was only the choice of an=versary or tax year? On Sat Se 26 2015 at 6:41 AM, Halperin, Alan <mailt > wrote: EFTA_R1_02042919 EFTA02694671

An annuity paid on the anniversary date is an annual annuity (and probably =he last annuity payment on other types of payment schedules). <tel Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison =LP 1285 Avenue of the Americas New York &=bs -NY 10019-6064 <tel (Direct Phone) (Direct Fax) <mailto <http://www.paulweiss.com> From: Jeffrey E. Sent: Saturday, September 26, 2015 1:09 AM To: Halperin, Alan S Subject: www.paulweiss.com https://www.law.cornell.edu/cfr/text/26/25.2702-3 chttps://www.law.cornell.edu/cfr/text/26/25.2702=3> =nbsp; i only see the limitation of the 105 day look back to be=based on anniversary date. i dont see the annual min req that you mentioned. please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved This message is intended only fo= the use of the Addressee and may contain information that is privileged a=d confidential. If you are not the intended recipient, you are hereby noti=ied that any dissemination of this communication is strictly prohibited. If you have received this communicat=on in error, please erase all copies of the message and its attachments an= notify us immediately. please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for 2 EFTA_R1_02042920 EFTA02694672

the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved date-last-viewed 0 date-received 1443280543 flags 8590195717 gmail-label-ids 7 27 remote-id 546567 3 EFTA_R1_02042921 EFTA02694673