It has recently been determined that an investment that was to have been been made in the name of Financial Trust Company, Inc., ("FTC"), an Economic Development Commission ("EDC") beneficiary, via The Haze Trust ("THT"), was inadvertently titled in the name of Jeffrey Epstein individually. It was further noted that the trust was also formed incorrectly as a grantor trust of which Mr. Epstein was the both the grantor and the beneficiary. Due to the contemporaneous nature of the formation of both FTC and the THT and the clear recollection of the parties involved in the formation of the entities, the conclusion that THT was at all times intended to be to be the owner of the investment and wholly owned by FTC is reasonable. Shortly after its formation in 1999, The Haze Trust made investments in several hedge funds, including Highbridge Capital Corporation ("HCC"). These investments generated substantial income, much of which was passive foreign investment company ("PFIC") ordinary income and capital gain. A qualified electing fund election ("QEF") was made with respect to such investment. Although a United States shareholder in a QEF is currently taxed on its undistributed earnings, the shareholder may elect annually to defer the payment of the tax on those earnings, subject to an interest charge. IRC §1294(a)(1). Specifically, Section 1294(a) provides for the extension of payment of any "undistributed PFIC earnings tax liability." This term is defined as the excess of the tax imposed for the EFTA01128412