From: "jeffrey E." <[email protected]> To: Heather Gray Subject: Re: yesterday's meeting with Leon Date: Sat, 25 Oct 2014 00:30:04 +0000 thanks you are on the right track On Fri, Oct 24, 2014 at 4:21 PM, Heather Gray Dear Jeffrey, > wrote: I wanted to update you on my meeting with Leon and Rich Joslin yesterday afternoon. We had planned to identify which works of art should be held in the new art entity, but it turned into a much broader discussion about the overall plan for the art. • Art/Black Family Museum Prompted by your question to Leon about whether there are particular works of art that the children may want to keep after his death, he articulated a desire for maximum flexibility, a theme which you have been stressing all along. He noted that the children are in a different place in their lives today than they will be in 10 or 15 years, so it would be very difficult for them to say with any certainty today which works they would want to keep forever. He also wants to have the option to move art out of the new entity in the future and use it to fund a "Black Family Museum," should his non-art assets grow substantially in the coming years. His reasoning is that, under this scenario, the children would receive substantial non-art assets at his death so the art would not have to be sold and instead could be used to create a family legacy. The discussions that I have been involved in with respect to the new art entity do not contemplate this option, so we will need to do some broader thinking with Alan about how to give Leon this flexibility without running afoul of 2036. For example, the draft agreement only allows a member to withdraw from the company or reduce his capital account with the consent of the Class B Managing Members (i.e., the trustees of the children's trusts). This makes perfect sense from an estate tax/discount standpoint, but does not necessarily accomplish what Leon wants. An interesting side note to come out of