Wednesday, August 22, 2012 U.S. Trust Comments to Leon Black Revocable Trust. Comment 3.1 Since most of Leon's art is owned in entities (Narrows Holdings I and Narrows Holdings II), I assume you will need a specific disposition of those entity interests so that such interests pass (i) to the Marital Trust if Debra survives Leon or (ii) per stirpes to Leon's issue subject to the trusts held under the Black 2006 Family Trust if Debra predeceases Leon. As drafted, these LLC interests would pass as part of the residuary trust fund : 1/2 to the CLATs and 1/2 per stirpes to Leon's issue subject to the trusts under the 2006 Family Trust. Comment 6.1 Since you anticipate that Leon will not fund his revocable trust during his lifetime, if Debra survives, consider disposing of tangibles and residences under the Will so that title does not need to be changed twice—once to the Trustees of the Revocable Trust and again to the Marital Trust or Debra. Comment 6.2 Include in the definition of residences, interests In any entity that owns a residence used by Leon as a personal residence? Comment 7.1 I understood that the impetus for Leon giving half his estate to charity if Debra predeceases is that he felt his children had already received enough assets. If that is so, why not simply leave Share A to the Black Family Foundation, rather than create four separate CLATs? I think we should raise this with Leon. Riders to Page 22: 22.1 or at the time of the Senior's death if DEBRA shall survive the Settlor. 22.2 (the "Issue's Share") shall be further subdivided into two separate shares according to value: (1) one share consisting of that portion of the Issue's Share having a fair market value at the time of division substantially equal to seventy-five percent (75%) of the total fair market value of the Issue's Share (Share A), and (2) one share consisting of the balance of the Issue's Share ("Share Be). 1 EFTA01127310