EFTA02016371.pdf

To: McCaffrey, Carly From: Jeffrey Epstein Sent Sat 11/17/2012 1:44:13 PM Subject: Re: (WARNING: MESSAGE ENCRYPTEDJFW: Leon Black - form 709 now that i see you already awake? ive read many of the creditor cases , including the group i sent. possible idea 1. either before or after we change to an adversarial trustee. , leon gifts the right to dcbra. .. I can find no case that deals with the compound transaction of cutting off a trust right to spouse. ( a right especially that cannot invade the whole trust. ) not the settlor - though fraudulent transfer etc. could apply. 2. decant the trust. . 3. new three- tiered partnership. is management interest residual interest and preferred. ( coupon of preferred to be discussed, may be variable ) 4. decide on rectifying payout mistake not related to "relevant coS 5. Since the trust is a partner in black family partners can we reorg the partnership so that it cannot distribute any cash to 2006 trust „ hence no trust acct income. . and Icon gets his money through the gp interest instead.? Im around all weekend at home MM. On Sat, Nov 17, 2012 at 7:45 AM, McCaffrey, Carlyn < =••wrote: Leon's 709 shows that he still had $1.74 million of gift tax credit left at the beginning of 2012. Can one of you check to see if he's made any taxable gifts during 2012 so that we know how much he has left. If he hasn't made any further gifts, the simplest approach is probably to have him make a gift to his 1997 GST exempt trust. Carlyn S. McCaffrey Partner McDermott Will & Emery LLP I 340 Madison Avenue. New York, NY 10173 \MTN. rnwe.com From: Kirschner, Elyse Sent: Friday, November 16, 2012 5:58 PM To: McCaffrey, Carlyn Subject: FW: Leon Black - form 709 Here's Leon's 2011 gift tax return (the code to open the return is 10018). Leon used $1.0 million of his gift tax credit through 2010. In 2011, he made taxable gifts of $2374 million. So, he still has about $1.74 million of his credit left. EFTA_R1_00519608 EFTA02016371 He used $3.5 million of his GST exemption. He should just make a gift of $1.5 million to his 1997 GST exempt trust. Elyse G. Kirschner I Partner McDermott Will_& Eme LLP 340 Madison Avenue, New York, NY 10173 ww mwe com From: Thomas Turrin Sent: Friday, November 16, 2012 5:34 PM To: Kirschner, Elyse Subject: RE: Leon Black - form 709 Elyse, The p/w is my office zip code. I will send Debra's on Monday. Best, Tom THOMAS TURRIN, CPA Partner Raich Ende Malter & Co. LLP EFTA_R1_00519609 EFTA02016372 1375 Broadway New York, New York 10018 irect line) ax) ell) Email: Website: www.rem-co.com From: Kirschner, Elyse Sent: Friday, November 16, 2012 3:55 PM To: Thomas Turrin Subject: RE: Leon Black Thanks. Can you send me Debra's too? Elyse G. Kirschner Partner McDermott Will & Emery LLP 1340 Madison Avenue, New York, NY 10173 www.mwe.com From: Thomas Turrin Sent: Friday, November 16, 2012 3:54 PM To: Kirschner, Elyse Subject: RE: Leon Black I will forward it to you a little later. EFTA_R1_00519610 EFTA02016373 THOMAS TURRIN, CPA Partner Raich Ende Malter & Co. LLP 1375 Broadway New York, New York 10018 ;red line) 'ax) ell) Email: NVebsite: www.rem-co.com From: Kirschner, Elyse Sent: Friday, November.... To: Thomas Turrin Subject: Leon Black Torn, Do you have a copy of Leon's 2011 gift tax return? EFTA_R1_00519611 EFTA02016374 Thanks. Elyse Elyse G. 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