From: William Blum Sent: Wednesday, September 21, 2016 11:22 PM To: Jeffrey E. ([email protected]) Cc: Robert Ladislaw Subject: NIIT provisions Dear Jeff —</=> I wanted to revisit this issue which we talke= about on the phone. As presently drafted, the provision would actua=ly allow the BIR to pursue taxpayers who did not pay this tax for the 2013=through 2015 tax years based on a 6-year statute of limitations instead of=3 years and it also allows a reduced penalty (5%) for those years for taxp=yers who pay before audit — sort of like an amnesty. I expect =hat this would actually be a revenue raiser so the Governor should be happ= with it. Should I leave that in? Also, as presently drafted, VI source dividends and interest=would not be subject to the tax for future years (starting in 2017). =1 think that would have little impact actually since the money maker for t=e Government here is capital gains and that would not be exempted. B=t exempting VI source income and dividends is an incentive (albeit a small=one) to invest in USVI entities and to lend money to VI persons. Sho=ld I leave that in? I am=planning to get another draft out tomorrow, probably by mid-day. Feel free to call if you want to di=cuss. Yours,</=pan> Bill William Blum I Partner SOLOMON BLUM HEYMANN LLP &=bsp; &nbs=; &=bsp; 40 Wall Street, 35th floor New York, NY 10=05 Tel EFTA_R1_00083602 EFTA01771775