From: Thomas Turrin To: Jeffrey Epstein <[email protected]> Subject: RE: Re: Date: Tue, 21 May 2013 12:15:12 +0000 Inline-Images: image001.png; image002.jpg; image003.jpg Jeffrey, The reporting of gifts made by Leon on his return only is correct... Under Section 25I3(a) of the Code, a gift by a husband to a third party is considered to be made one-half by him and one-half by his wife as long as she is a citizen or resident of the US. However this rule applies only if both spouses have signified their consent to its application. When the wife does not consent the gift is from the husband only. I would, however, recommend that a different account be set up (not joint) — or perhaps a type of discretionary trust could be set up from which gifts can be made to whomever the grantor wishes — with no disclosure of donees on gift tax return necessary... the gift to the trust would be the reportable gift — I would discuss with estate and trust counsel. Trustee would make gifts in its discretion from trust account. Best, Tom THOMAS TURRIN, CPA Partner Raich Ende Malter & Co. LLP 1375 Broadway New York, New York 10018 Email: Website: www.rem-co.com From: Jeffrey Epstein [[email protected]] Sent: Monday, May 20, 2013 5:03 PM To: Thomas Turin Subject: Re: if the money comes from a joint acct, isnt it considered a 50/50 gift? EFTA00874301