From: jeffrey E. <[email protected]> Sent: Monday, April 17, 2017 10:44 PM To: Richard Joslin Subject: Fwd: Re: )?2 Forwarded mes=age From: jeffrey E. <jeevacation@gmail=com <mailto:[email protected]» Date: Mon, Apr 17, 2017 at 6:29 PM Subject: Re: R=: To: Richard Joslin < <mailto > > and the fees for structuri=g the phaidon transaction. ? as part of his income tax planning.7O=A0 I think so. dont you? <=r> On Mon, Apr 17, 2017 at 6:25 PM, Richard Josl=n c <mailto » wrote: I will get you the backup for estate =fanning nondeductibity From: jeffrey E. [mailto:[email protected]] Sent: Monday, April 17, 2017 6:18 PM To: Richard Joslin < <mailto Subject: Re: > > order to be deductible, the IRS <http://www.investopedia.com/terms=i/irs.asp> requires that estate planning fees <https://www.irs.gov/pub/irs-pdf/p550.pdf> must be paid: (1) for the production or collection=of income; (2) for the management, conservation or maintenance of property=held for the production of income; or (3) in connection with the determina=ion, collection or refund <http://www.investopedia.com/terms/r/refund.asp> of any tax. So how might this apply to estate planning fees? If, for example, the estate plan <http://www.investopedia.com/advisor-network/articles/051716/why-it=-so-important-update-your-estate-plan/> involves advice on the construction of income generating in=truments, such as an income trust <http://www.investopedia.com/terms/i/incometrust.asp> , or provides guidance on the use of property transf=r methods to avoid Federal or State Estate or Inheritance tax <http://www.investopedia.com/terms/e/estatetax.asp> , these would meet the I=S restrictions for the ability to deduct such expenses. Other examples mig=t include investment advice <http://www.investopedia.com/terms/i/investment-advice.asp> for trusts held by the estate, trust tax=preparation fees and account custodial fees while held by the estate EFTA_R1_01895991 EFTA02652637