From: "Governor Kenneth E. Mapp' To: jeffrey E. <[email protected]> Subject: Re: Legislation Date: Mon, 24 Oct 2016 17:26:35 +0000 Got it, thanks From: Jeffrey E. [email protected]> Sent: Sunday, October 23, 2016 10:49:10 AM To: Governor Kenneth E. Mapp Subject: Fwd: Legislation see you tues? Forwarded message From: William Blum <I Date: Tue, Oct 18, 2016 at 6:15 PM Subject: Legislation To: "jeffrey E. ([email protected])" <jeevacation®gmail.com> Dear Jeff — Attached is the proposed transmittal letter to the Legislature from the Governor. I tried to draft it as a mostly "political" document, as opposed to the Explanation section of the bill itself which is more technical and "explanatory." Please give me any comments. Please note that I have not yet included the repatriation provisions in the letter because (1) I have not drafted them yet, and (2) I am unsure of how you think the Governor will want to handle that issue politically. I have also attached a slightly revised version of the legislation itself. There are no substantive differences from version 7 which I sent you last week. The changes are in the Explanation section regarding section 1423 (taxation of statutory trusts — pp. 45-47) and in the name of bill (I changed 2016 to 2017 in the title). By the way, my thought about how to draft the repatriation provisions is to establish a special type of statutory trust that requires a very large capital investment, the 25 employees we talked about, and the requirement that the trust and its assets remain in the USVI for a minimum period of time, etc. Bill William Blum I Partner SOLOMON BLUM HEYMANN LLP 40 Wall Street, 35th floor New York NY 10005 Tel Fax Email please note EFTA00813687