EFTA02472768.pdf

From: jeffrey E. <jeevacation@gmail.com> Sent: Thursday, February 11, 2016 2:44 PM To: Richard Joslin Cc: Brad Wechsler; Richard J Bronstein; Melanie Spinella John Castrucci; Joe Avantario Subject: Re: Re: it says charter and OTHER , where is the apollo reim=ursement then ? what is the amount ? On Thu, Feb 11, 2016 at 9:37 AM, Richar= Joslin > wrote: The 42 hours include both Part 91 and=Part 135 hours. Part 135 is the charter component and that gives ris= to charter revenue. From: jeffrey E. [mailto:jeevacation@gmail.comj Sent: Thursday, February 11, 2016 9:21 AM To: Brad Wechsler Cc: Richard.' Bronstein >; Melanie Spinella >; John Castrucci >; Richard Joslin Subject: Re: it says charter revenue only 312 but letter sa=s apollo hours were 42 at 18k each hour? On Tue, Feb 9, 2016 at 6:41 PM, Brad Wechsler wrote: MEMORANDUM ATTORNEY•CLIENT PRIVLEDGE TO: =C2 Rick Bronstein =C2 =AO =C2 CC: =AO John Castrucci EFTA_R1_01584868 EFTA02472768  =AO Leon Black =C2 =AO =C2 =AO =C2 Joe Avantario =AO =C2 =AO =C2 =AO =C2 =AO Rich =oslin FROM: Brad Wechsler =AO =C2 =AO =C2 =A0 Jeffrey Epstein DATE: February 9, 2016 Leon, 1. Attached, please find the January 26th memo on the airplane which wa= sent to you previously. It deals with Part 91 vs. 135 and attendant costs=and income tax benefits. The office feels that with respect to income tax,=Part 135 is more favorable, but not significantly so, i.e., between 0 and $400K depending on use. 2. Also included are detailed operating costs. These were previously se=t to Jeffrey but not previously not sent to you. 3. The final note details the FET and sales tax consequences of moving =rom the current structure to a simplified structure. Were we to move to a =ery simple Part 91only structure you could likely save $200K/year but wou=d have to own and operate the plane in your personal name (your insurance is sufficient, but there would be a =ertain lack of privacy). If you held the plane in a sole purpose LLC the a=orementioned savings would disappear. If Jeffrey wants to take a deep dive= we have much detailed material and we would also suggest he speak to Rich.' and our aviation attorney.=/u> 4. Bottom-line, a lot of work has been done and there is not a compelli=g answer, one way or another. Taking into account income tax attributes, s=les tax attributes and ease of use attributes it's almost a push, =hough I would probably marginally favor Part 135. I believe Jeffrey favors Part 91, which in my mind, is a suffici=nt reason to go that route. We should discuss. Thanks 2 EFTA_R1_01584869 EFTA02472769  please no=e 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 JEE 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 <mailto:jeevacation@gmail.com> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please =ote The information contained in this communication is confiden=ial, may be attorney-client privileged, may constitute inside informati=n, and is intended only for the use of the addressee. It is the propert= of JEE Unauthorized use, disclosure or copying of this communica=ion or any part thereof is strictly prohibited and may be unlawful. If =ou have received this communication in error, please notify us immediat=ly by return e-mail or by e-mail to jeevacation@gmail.com <mailto:jeevacation@gmail=com> , and destroy this comm=nication and all copies thereof, including all attachments. copyright -=11 rights reserved 3 EFTA_R1_01584870 EFTA02472770