(=irect Phone) I (=irect Fax) I www.paulweiss.com <http://www.pau weiss.com> From: Jeffrey E. [mailto:[email protected]] Sent: Sunday, Februa 21 2016 5:15 AM To: Halperin, Alan Subject: Re: can the units be contributed to a donor advised fund=? are the exchanges limited by a 144 volume restriction. . is there an sec filing requirement on exchange . sale or bot=? On Sun, Feb 21, 2016 at 12:50 AM, Halperin, Alan S wrote: Ab=ent a tax-free exchange, the TRA is triggered at exchange. The units canno= be contributed to charity. Alan Al=n S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison =LP New York, NY 10O19-6064 (Direct Phone) (Direct Fax www.paulweiss.com <http://www.paulweiss.com> From: Jeffrey E. Sent: Saturday, February 20, 2016 4:32 PM To: Halperin, Alan S Subject: Re: understood. when is the tra triggered normally= when exchanged or when sold? can the units be don=ted to charity or does it carry ubti On Sat, Feb 20, 2016 at 11:56 PM, Halperin, Alan wrote: 4 EFTA_R1_01579562 EFTA02469240

Be=ore contribution to charity, a principal can exchange AOG units for AGM sh=res in a tax free exchange. After the contribution, charity can sell =8E. Under current TRA , there is no TRA payments associated with the foregoing steps. Alan Al=n S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison =LP New York, NY 10019-6064 (Direct Phone) (Direct Fax) www.paulweiss.com <http://www.paulweiss.com> From: jeffrey E. Sent: Saturday, February 20, 2016 3:48 PM To: Halperin, Alan S Subject: Re: tax free exchange, is that the same as d=nating the stock to charity.. if the charity sells the stock , what happends to the step up On Sat, Feb 20, 2016 at 11:25 PM, Halperin, Alan S &=t;ahalperin@p=ulweiss.com <mailto:[email protected]» wrote: Un=er TRA, no TRA rights are triggered in connection with a tax-free exchange= Alan Al=n S. Halperin I Partner Paul, Weiss, Rifkind Wharton & Garrison =LP 1 New York, NY 10019.6064 (Direct Phone) I MIN (Direct Fax) www.paulweiss.com <http://www.paulweiss.com> From: jeffrey E. Sent: Saturday, February 20, 2016 2:04 PM To: Halperin, Alan S Subject: what happened to rowens tra when he donated the shar=s in may of 14 5 EFTA_R1_01579563 EFTA02469241

please no=e 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 for the use of the Addressee and may cont=in information that is privileged and confidential. If you are not the int=nded recipient, you are hereby notified that any dissemination of this communication is strictly prohibited. If you hav= received this communication in error, please erase all copies of the mess=ge and its attachments and notify us immediately. please no=e 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 6 EFTA_R1_01579564 EFTA02469242

please no=e 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] <[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please no=e 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 please no=e 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] <[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 7 EFTA_R1_01579565 EFTA02469243

please no=e 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 please =ote The information contained in this communication is confiden=ial, may be attorney-client privileged, may constitute inside informati=n, and is intended only for the use of the addressee. It is the propert= of JEE Unauthorized use, disclosure or copying of this communica=ion or any part thereof is strictly prohibited and may be unlawful. If =ou have received this communication in error, please notify us immediat=ly by return e-mail or by e-mail to [email protected] <mailto:jeevacation@gmail=com> , and destroy this comm=nication and all copies thereof, including all attachments. copyright -=11 rights reserved 8 EFTA_R1_01579566 EFTA02469244