From: Jeffrey E. <[email protected]> Sent: Thursday, January 21, 2016 12:40 PM To: Brad S Karp I have a call today with Alan Halperin et al.. There is obviosly, , no gu=rantee of a solution however, I would be willing to pay for the work=myself so there is little argument to my role in this. if you =hink a separate matter billing helps with clarity„ I recogni=e it would not be perfect.: the subj=ct is apollo/ athene. - rot=schild.( possible ) USVI less likely . t=e subjects will require a thorough review of BRH agreement , the agreem=nt amongst principals. , TRA, etc. consequences on death. = all , likely to require some amendments, =he solution if one exists will likely involve. partnership reg=. taxes, accounting. , insurance reg and restrictions . = on -shore and off- shore. personal income tax. PFIC or CFC, . sec disc=osures.- restrictions. review of tolls on foreign trans=ction regs. not limited to 356- 7 . out bound etc.=C2 possible restrictions on inversions, Charitable trusts.=C2 ( broad category CLT CRT nimcrut, and full e=tate considerations . including taxes and disdos=res. some valuation questions will need to be dealt with as well as non un=formity amongst founders - due to difference in age. ( discou=t rate for TRAaspan> , termination calculation? fairness etc. ). It app=ars obvious that the future of the PE biz at scale cannot be built around =eats , but asset JEE Unauthorized =se, disclosure or copying of this communication or any part thereof is =trictly prohibited and may be unlawful. If you have received this co=munication in error, please notify us immediately by return e-mail or b= e-mail to jeevacation <mailto:[email protected]> @g=ail.com, and destroy this communication and all copies thereof, =nduding all attachments. copyright -all rights reserved 4=iv> EFTA_R1_0 1587334 EFTA02474598