EFTA01979869.pdf

To: Thomas Turrin McCaffrey, Carlyn : Eileen Alexanderson Cc: Jeffrey Epstein(jeevacation@gmail.com] From: Kirschner, Elyse Sent: Mon 11/19/2012 7:49:11 PM Subject: RE: Leon Black - form 709 I think we should still consider whether Leon wants to make a taxable gift subject to gift tax to the Black 1997 Family GST Exempt Trust to use the remainder of his GST exemption. Elyse G. Kirschner' Partner From: Thomas Turrin [mailto Sent: Monday, November 19, 2012 2:45 PM To: McCaffrey, Carlyn; Eileen Alexanderson Cc: Kirschner, Elyse; Jeffrey Epstein Subject: RE: Leon Black - form 709 Carlyn, Leon has nothing left of his lifetime exemption. His year 2012 gifts to date are slightly over 2.5 million. Best, Tom EFTA R1_00467670 EFTA01979869 THOMAS TURRIN, CPA Partner Raich Ende Malter & Co. LLP From: McCaffrey, Carlyn Vialite: Sent: Saturday, November 17, 2012 7:46 AM To: Thomas Turrin; Eileen Alexanderson Cc: Kirschner, Elyse; Jeffrey Epstein Subject: [WARNING: MESSAGE ENCRYPTED]FW: Leon Black - form 709 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. EFTA_R1_00467671 EFTA01979870  Carlyn S. McCaffrey I Partner McDermott Will & Emery LLP I 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 52.374 million. So, he still has about $1.74 million of his credit left. 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 & Emery LLP I From: Thomas Turrin [nal Sent: Friday, November 16, 2012 5:34 PM To: Kirschner, Elyse Subject: RE: Leon Black - form 709 Elyse, The p/w is EFTA R1_00467072 EFTA01979871 I will send Debra's on Monday. Best, Tom THOMAS TURRIN, CPA Partner Raich Ende Malter & Co. LLP From: Kirschner, Elyse [mailko Sent: Friday, November 16, 2012 3:55 PM To: Thomas Turrin EFTA_R1_00467673 EFTA01979872 Subject: RE: Leon Black Thanks. Can you send me Debra's too? Elyse G. Kirschner I Partner McDermott Will & Emery LLP From: Thomas Turrin US. Sent: Friday, November 16, 2012 3:54 PM To: Kirschner, Elyse Subject: RE: Leon Black I will forward it to you a little later. THOMAS TURRIN, CPA Partner Raich Ende Malter & Co. LLP EFTA_R1_00467674 EFTA01979873 From: Kirschner, Elyse [mailto Sent: Friday, November 16, 2012 3:21 PM To: Thomas Turrin Subject: Leon Black Torn, Do you have a copy of Leon's 2011 gift tax return? Thanks. Elyse Elyse G. Kirschner Partner McDermott Will & Emery LLP 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. 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CIRCULAR 230 DISCLOSURE: To insure compliance with requirements imposed by the Internal Revenue Service. we inform you that any tax advice contained in this communication (Including any and all attachments). unless expressly stated otherwise. was not intended or written to be used and cannot be used for the purpose of (i) avoiding tax-related penalties imposed by the Internal Revenue Code or NO promoting. marketing. or recommending to another party any transaction(s) or tax-related matter(s) addressed herein. This communication may not be forwarded (other than to the addressee(s) identified above) without our express written consent. EFTA_R1_00467676 EFTA01979875