that, where a grantor trust is the lender, the grantor would be subject to income tax on imputed interest. Alan S. Halperin I Partner Paul, Weiss, Ftificind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019.6064 From: Halperin, Alan S [mailto: Sent: Wednesday, September 17, 2014 5:27 PM To: Ada Clapp