From: McCaffrey, Carlyn Sent: Friday, February 7, 2014 5:27 PM To: Jeffrey Epstein ([email protected]) Subject: FYI http://servi=es.taxanalysts.comitaxbase/stn3.nsf/(Number/2014+STT+26-33?OpenDoc=ment&Login chttp://services.taxanalysts.comitaxbase/s=n3.nsfANumber/2014+STT+26-33?OpenDocument&Login> Transfers of Property Between Settlor and Grantor Trust Su=ject to New York Sales Tax Citations: TSB-A-14(6)S; Petition =o. 51310O7A <1=> The New York State Department of Taxation and Finance explained that when a=settlor transfers property to a grantor trust or a revocable living trust =n exchange for trust property, the transfer is subject to sales tax becaus= an exchange has been made between two separate entities, even if there is no negotiation and the transfer is=not supported by consideration. Sales Tax January 29, 2014 ADVISORY OPINION The Department of Taxation and Finance received a Petition for an Advisory =pinion from ' ' ' name and address redacted ' ' ' . Petitioner requests gu=dance on whether the substitution of property between himself and the trus= is subject to sales and use taxes in New York. EFTA_R1_01952459 EFTA02673779