From: jeffrey E. <[email protected]> Sent: Monday, September 25, 2017 3:27 PM To: Melanie Spinella Subject: HE is reading articles and sending questions THIS IS NOT SCHOOL From: Joseph Vinciguerra imailto Sent: Monday, September 25, 2017 10:43 AM To: Wimer, Ruth Cc: Deyoe, David; Barry J. Cohen; John Castrucci Subject: FET Question Hi Ruth, We had previously discussed how Part 91 operations were not subject to FET. Take a look at the attached article, specifically the highlighte= section on page 4. In reading the CCA the article refers to (also attached), it seems like the IRS is taking the position that management agreements under Part 91 operations are subject to FET. Being that the CCA is from 2012, I would think=20 there has been some time to sort through the IRS' position. What are your thoughts on this and how it cou=d apply to our structure? Thanks. Joe Joseph M. Vinciguerra I Tax Director & Tax Counsel Elysium Management LLC I EFTA_R1_01796525 EFTA02605828

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