From: jeffrey E. <[email protected]> Sent: Monday, May 9, 2016 12:03 PM To: Melanie Spinella Subject: Fwd: S Forwarded messa=e From: Brad Wechsler < Date: Mon, May 2, 2016 at 11:53 AM Subject: Re: [email protected] <mailto:[email protected]> &q=ot; <'eevacation :mail.com <mailtofeevacation mail.com> = t• Jeffrey-let me give you the top-line and others =an fill in as necessary on the issues noted below and progress. 1. BRH k: key point is that both apo and pw have indicated that their read =s that no two principals can take an action that is prejudicial to the thi=ds estate. This is key but must be socialized with marc and josh (by john =) and then be clearly reflected. A. Of lesser importance, wendy is trying to push thru the 754 election at a= professionals, make certain an estate has access to "information rig=ts", see if the three partners want mfn investment rights to continue=past death and fix some language "clarifications. Wendy is quarterbacking this and timing is apo dependent which means likely=to be a process. On some none "fire-drill" issues which are nonetheless quite impt= pls note: 2. People are comfortable with TRA transfer with respect to 2007 stock sale= and, I believe, are expressing "sufficient comfort" with respec= to a TRA transfer for future sales. There are definitely imbedded issues =ith respect to "completed gifts" and creating a separation from BRH without causing tax effects. Nonetheless, it appears=we'll come out ok. 3. TIC still appears somewhat problematic to alan or said differently: I do='t believe AH is comfortable with "nominal ownership and exclusiv= use". 4. We (and you) now know that a clat works and we can have an ultimate bene=iciary as the foundation, a clat or both. You, leon and alan have to decid= whether you want to "hard wire" the clat into the planning coda= (can do one that has some built in flexibility) or defer to a later date. 5. By later today or tomorrow I shld be ab