From: Richard Joslin To: Jeffrey Epstein <[email protected]> Subject: FW: question on interest Date: Wed, 25 Mar 2015 19:42:23 +0000 Let's discuss at 4:45 (if there is time) Re Interest paid by Phaidon Press (UK) to Phaidon Global (US) As you know, the payment of interest by a UK person to a non-UK person may give rise to UK income tax withholding of 20%. In order to claim the benefits of reduced withholding under the UK/US income tax treaty, the UK requires the lender to file forms with UK taxing authorities (HMRC). The certified claim procedure requires the lender to obtain IRS certification of US status (routine and common for withholding matters). An expedited process is a double taxation passport scheme. With the passport, all debt issued is covered by the passport. The lender will be listed in HRMC public database. No IRS certification of US status is needed. Note I indirectly reached out to BDO (Phaidon tax and accounting firm) and they provided some explanation below. The author has never undertaken either the claim or passport procedures. Note that there were repayments of the credit line in 2014. Let's discuss. Concern 1: if we are going down the road of registering the debt with UK to avoid UK withholding, we are late in doing so, and this goes for the grid note and the other notes from Phaidon Global to Phaidon Press/ or PLB to JMWT Ltd. Concern 2: if we forego registering to avoid withholding, then we are late in remitting the UK tax. I don't know what lateness is less desirable; I would think the latter. Begin forwarded message: From: Peter Goodwin Date: March 24, 2015 at 6:10:57 AM EDT To: "Richard Joslin Cc: John Murphy < Subject: FW: question on interest Hi Richard, Please find attached the response from BOO regarding the loan from Global to PPL. Please advise how you would like to proceed. Regards Pete From: James Rissen Sent: 23 March 201 . To: Peter Goodwin Cc: James Pratt Subject: RE: question on interest H