From: jeffrey E. <[email protected]> Sent: Monday, April 17, 2017 11:14 PM To: Thomas Turrin Subject: Fwd: Fwd: Forwarded messa - From: Halperin, Alan S < <mailto Date: Mon, Apr 17, 2017 at 7:08 PM Subject= RE: Fwd: To: "jeffrey E." <[email protected] <mailto:jeevacation@=mailcom» > > Under Treas. Reg. 301.6501(c)-1(f)(2)=iii), in order for there to be adequate disclosure and start the statute o= limitations, among other things, the tax return must include "a brief description of the terms of the trust, or in=lieu of a brief description of the trust terms, a copy of the trust instru=ent." Most accountants include a copy of the trust agreement=because (i) it is a certainty that such inclusion satisfies this requirement and (ii) it does not require any drafting. However,=the regulations clearly state that "a brief description of the ter=s of the trust" would be sufficient. Alan S. Halperin I Partner (Bio=/a>) Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019-6064 <https://www.paulweiss.com/professionals/partners- and=counsel/alan-s-halperin.aspx?utm_source=signature> (- <tel: -> (Direct Phone) <tel: > (Direct Fax) <mailto > www.paulweiss.com <http://www.paulweiss.com> From: jeffrey E. [mailto:[email protected]] Sent: Monday, April 17, 2017 6:20 PM To: Halperin, Alan S < <mailto Subject: Fwd: > > is it your position that a summary of the trust docu=ent with a note that says full document available upon request. and =ttached to a tax return leaves it open to be deemed / =AO not adequately disclosed ??! Forwarded =essa e From: Thomas Turrin < <mailto > > Date: Mon, Apr 17, 2017 at 6:17 PM Subject: RE: To: "jeffrey E." <[email protected] <mailto:[email protected]» EFTA_R1_01896164 EFTA02652769