seph Vinciguerra , Brad Wechsler Cc: Richard Joslin , John Castrucci Subject: Advisor fee deductions-PRIVILEGED AND CONFIDENTIAL On a call today, David Kirk at EY made a case for the following approach to deducting advisor fees that involved setting up and structuring (construed fairly broadly) a new dis

> Cc: Richard Joslin <mailto > >, John Castrucci <mailto: > Subject: Advisor fee deductions--PRIVILEGED AND CONFIDENTIAL<=r> On a call today, David Kirk at EY made a case for th= following approach to deducting advisor fees that involved setting up and=structuring (construed fairly broadly) a new dis

audits > > EFTA_R1_01814672 EFTA02615307 Significant number of NYS and CT — Statutory residency, dom=cile and income allocation audits </=pan> David Kirk =80 Partner— National Tax PCS * Spends 75-100 hours a year on audits * About 50% of the audits are Global High Wealth</=> * Most of the matters

newsroom/news-releases/news-bcrs-associa=es- Ilc-members-join-ey-private-client-services> Relationship guy, but has good pro=lem-solving judgment • David Kirk, EY, https:=/www.law.georgetown.edu/faculty/kirk-david-h.cfm# <https://www.law.georgetown.edu/faculty/kirk-david-h.cfm#> , depreciation and p=rtners