EFTA02357208.pdf

From: Eileen Alexanderson Sent: Tuesday, October 22, 2013 8:27 PM To: 'Ada Clapp; Alan S. Halperin; Jeffrey Epstein Subject: RE: Timing of Funding GRAT I have confirmation the 3Q dividend wi=l be paid on November 29th but ex-div date has not yet been set-wi=l let you know when I do. From: Ada Clap= [mailto:. Sent: Tuesday, October 22, 2=13 4:23 PM To: Alan S. Halperin; Jeffre= Epstein Cc: Eileen Alexanderson Subject: Re: Timing of Fundi=g GRAT Hi Jeffrey and Alan, I spoke with today and it is my impression that he wants to wait to fund the GRAT until after the ex-dividend date (so that he can get the dividend and so the valu= of what he transfers to the GRAT will possibly be lower). Regarding the marital deduction issue, please Step 3 in the attache= article which explains why the productive of income language is included in=the GRAT. Alan--I used to include the following language (one time)=in the trust boiler plate where there was a marital trust included, so I am fi=e with your proposed solution. <=>Ada=b> Clapp Black Family Partners<=r> c/o Apollo Management IRS Circular 230 Disclosure: Pursuant to IR= regulations, I inform you that any tax advice contained in this communicati=n (including attachments) is not intended or written to be used, and cannot b= used by any person or entity for the purpose of (i) avoiding tax related penalties imposed by any governmental tax authority, or (ii) promoting, marketing or recommending to another party any transaction or matter discus=ed herein. I advise you to consult with an independent tax advisor on your particular tax circumstances. EFTA_R1_01342719 EFTA02357208 This communica=ion, and any attachment, is for the intended recipient(s) only and may contain information that is privileged, confidential and/or proprietary If yo= are not the intended recipient, you are hereby notified that further dissemination of this communication and its attachments is prohibited. Please delete all copies of this communication and its attachme=ts and notify me immediately that you have received them in error. This email and any files transmitted with it are confidential and intended solely for the person or entity to whom they are addressed and may contain confidential and/or privileged =material. Any review, retransmission, dissemination or =other use of, or taking of any action in reliance upon this information by persons or entities other than the intended =recipient is prohibited. If you have received this email in =error please contact the sender and delete the material from =any computer. Apollo Global Management, LLC =0 2 EFTA_R1_01342720 EFTA02357209