From: Eileen Alexanderson To: 'Jeffrey Epstein' [email protected]> Subject: RE: FW: Debra Black Date: Mon, 03 Dec 2012 20:12:26 +0000 Thanks Elyse, working with Jeffrey on this. Will let you know what is decided. From: Jeffrey Epstein [mailto:[email protected]] Sent: Monday, December 03, 2012 3:06 PM To: Eileen Alexanderson Subject: Re: FW: Debra Black no payment now On Mon, Dec 3, 2012 at 8:50 PM, Eileen Alexanderson < wrote: From: Kirschner, Elyse [mailto: Sent: Monday, December 03, 2012 12:30 PM To: Eileen Alexanderson Cc: Thomas Turrin; McCaffrey, Carlyn Subject: Debra Black Eileen, ] Tom Turrin sent me Debra's last gift tax return (2007). It looks like Debra has already used $1 million of her gift tax credit on gifts from 1988 through 2005. As of 2007, she had used only $53,596 of her GST exemption. Has Debra made any taxable gifts or allocated any portion of her GST exemption earlier this year? Assuming that the answer to this question is no, Debra can gift to her new trust up to approximately $4.12 million before the end of the year without paying any gift tax. However, she has $5,066,404 of her GST exemption remaining. She may want to transfer to the new trust $5,066,404 and allocate her entire remaining GST exemption to the new trust, even if it means paying gift tax (at a 35% rate) on an amount equal to the difference between $5,066,404 and $4,120,000. It may be worth it for her to pay some gift tax to enable her to get an additional $950,000 of GST exempt property into the trust. Please let me know if you have any questions. Elyse Elyse G. Kirschner I Partner McDermott Will & Emery LLP ten *************Iv *A* ********* *alp • *to • *********** 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 t