To: Erika Kellerhals From: Jeffrey Epstein Sent: Fri 1/4/2013 1:38:57 PM Subject: Re: so what structure would work, for the bank? do i , or do they own the cumalitve preferred, ? what limits , how do they get a tax deferral with little risk On Fri, Jan 4, 2013 at 8:51 AM, Erika Kellerhals < wrote: If you own bulk of cs its okay Also depends on types of income company is generating Active vs non-active income Erika A. Kellerhala Partner Kellorhals Ferguson Fletcher Kroblin LLP Notice: This communication may contain privileged or other confidential information. If you are not the intended recipient. or believe that you have received this communication in error. p'ease do not print. copy. re-transmit. disseminate. or otheninse use this information. Also. please Indicate to the sender that you have received this e-mail in error. and delete the copy you received. Thank you. Circular 230: To ensure compliance with the requirements imposed by the IRS. we inform you that any tax advice contained in our communication (including any attachments) was not intended or •written to be used. and cannot be used. for the purpose or 0) avoiding any tax penalty or re) promoting. marketing or recommending to another party any transaction or matter addressed herein. From: Jeffrey Epstein <[email protected]> Date: Friday, January 4, 2013 8:49 AM To: Erika Kellerhals Subject: Re: so if us residents own common shares in our new bank,? why is my holding of a 100 percent intrest as a us person not included, On Fri, Jan 4, 2013 at 8:32 AM, Erika Kellerhals wrote: EFTA_R1_00346573 EFTA01910521