EFTA00635698.pdf

From: "McCaffrey, Carlyn" To: Jeffrey Epstein <jeevacation@gmail.com> Subject: RE: Date: Tue, 21 May 2013 11:28:40 +0000 Farkas - waiting for him to send back the engagement letter Zuckerman - am reviewing his documents Your question - If you contribute an installment debt owed to you to a charitable trust, you may be entitled to an upfront deduction for the current fair market value of the debt. A couple of caveats - 1. If the charitable trust is a private foundation as distinguished, for example, from a charitable remainder trust that will terminate in favor of public charities, your deduction will be limited to your basis in the debt. 2. If the installment debt was acquired by you in exchange for appreciated property, as the payments are made on the debt, your contribution of the debt to the trust will be a gain recognition event under section 4538. If this is the case, caveat #1 is probably not a concern, but would want to do a little research to make sure. 3. If payments on the installment debt would be ordinary income to you, I will have to give more thought to your question. Carlyn S. McCaffrey I Partner McDermott Will & Emery LLP 340 Madison Avenue. New York, NY 10173 From: Jeffrey Epstein [maittoleemcation@gmalLoom] Sent: Monday, May 20, 2013 9:24 AM To: McCaffrey, Carlyn Subject: farkas zuckerman? things going ok? if there is instalment debt coming due ogver the next ten years, can i contribute the stream to a charitable trust„ to i get the present value deduction, or as it comes in, 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 Jeffrey Epstein 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 jeevacation@gmail.com, and EFTA00635698 destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved t**** ***** IRS Circular 230 Disclosure: To comply with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained herein (including any attachments), unless specifically stated otherwise, is not intended or written to be used, and cannot be used, for the purposes of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter herein. This message is a PRIVILEGED AND CONFIDENTIAL communication. This message and all attachments are a private communication sent by a law firm and may be confidential or protected by privilege. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of the information contained in or attached to this message is strictly prohibited. Please notify the sender of the delivery error by replying to this message, and then delete it from your system. Thank you. ***** **a* Please visit for more information about our Firm. EFTA00635699