asus 143.565 143.565 0 0 0 Narrows REDON. ODILON Le cerf volant 200.000 200.000 0 0 0 Page 32 EFTA00592259 ALL ART - 3/19/17 Owner AP Narrows Artist REMBRANDT HARMENSZ. VAN RIJN Title Saint Jerome in an Italianate Landscape' Basis 800.000 CHRISTIE'S 5/11/16 appraised value or p

MBRANDT HARMENSZ. VAN RIJN Self-Portrait drawing at a Window 11/15/2016 395,000 400.000 5.000 5.000 0 EFTA00792629 2016 Purchases Owner AP Narrows Artist ZUCCARO. TADDEO Title Projet de decor de chapelle avec une Annonciation entournee de saint Paul, saint Georges, saint Augustin et un au

ed the point that there is a "bona fide sale" exception to Section 2036 and asked whether we still need to restrict Leon's powers as a Class A GP of AP Narrows if in the future he sells, rather than gifts, his LP interest in AP Narrows. Your point, as I understand it, is that Leon could have all the power o

$2.339.634.000 Sources • Transfer 51.003.885.030 of art to sandy. n part. debt of SI.438 bilion owng to (emery. truslanStos pnduding riterests in AP Narrows. Narrows Holdings US. Narrows Holdings II LLC and Pont Noldngs Inc.)' • Sell $431.277.000 worth of art and datnbute proceeds to busts lo minty. in p

the following approach to deducting advisor fees that involved setting up and structuring (construed fairly broadly) a new disregarded entity, like AP Narrows, and others. 1. Find entities which were set up a. within the last 2 years, and b. the advisor expenses were incurred prior to an entity's starti

o if the trusts purchase the Dante and then contribute their interests in the Dante to AP =arrows LP in exchange for limited partnership interests, AP Narrows will b= treated as a partnership for income tax purposes (not a pass-through enti=y). I'm not sure where you and Leon came out on th= question of wh

ws Timeline (5.15.15).pdf Hi Jeffrey, Attached is the timeline Brad asked me to put togeth=r listing the steps leading up to the initial funding of AP Narrows. =Brad and I will give you a call on Monday for your comments. Have a nice weekend! Ada Clapp Chief Legal Officer Elysium Management LLC 445 Pa

ership for income tax purposes (not a pass-through enti=y). I'm not sure where you and Leon came out on =he question of whether you would prefer for AP Narrows to be a disregarded=entity for income tax purposes or taxed as a partnership, so I just wanted=to flag this to you. Best, Heather Heather Gray E

Subject: FW: recent art purchases Question to JEE so as =o clarify 1)&n=sp; Going forward =#8211; which entity should be purchaser fo fine art: AP Narrows or N=rrows LLC? (You noted Narrows but want to make sure which Narrows en=ity) 2)&n=sp; There has been=instruction to transfer recent acquisitions

vvrot=: Meaning ... AP Narrows (seller of G=acometti) makes the commitment to the buyer to rescind the sale and refund=the purchase price, and then AP Narrows buys insurance from Leon to cover the authenticity risk? I'm not =ure I'm following you. From: jeffrey E. [mailto:[email protected] Sent: Sat