From: Barry J. Cohen Sent: Saturday, August 19, 2017 2:14 PM To: Jeff Epstein Subject: Fwd: Planning¶
Apollo flight is one that qualifies for Apollo reimbursement and Apollo p=ys for.
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Pro forma depends on when Apollo gives us data. Hopefully very soon.
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Gift tax case wasn't "advice". Just a blurb Joe read in a publication. =e might well have got it wrong. It was just something he thought he rememb=red and mentioned in passing. He was making the point that it might be a =ad idea for a tax return to have info that is factually wrong even if the =ax is right. Whether the case exists or not, that advice hardly seems craz=.
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Joe V is the best person we saw and is doing a great job. We have hired t=p lawyers and accountants. Always glad to see better people but we are not=finding them. And very hard to find jacks of all trades. We tend to see n=rrow expertise.
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S&C reviewed our estate planning and basically said everything we are doi=g is fine. EY reviewed our income tax planning and has been helpful, but h=s not had great suggestions for changing anything.
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If you see specific things we should be doing differently let us know wha= they are. If you know of people who will have greater insight than the on=s we are using, we are eager to talk to them.
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I too wish Leon would sell more art. We may have losses to partially off=et art gains. To the extent we do not, as you have pointed out, getting a =tep up on death may be preferable for the pieces with gain. In any event, =e don't know if Leon is willing to sell. So we cannot plan around that. My=goal is to be able to tell him "If you sell certain art you will achieve t=e following benefits." Not quite there yet.
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On the CLATs, I hear you that no one has experience with art. But as you =ave pointed out, Leon's situation is unique. Unless we hear specific reaso=s why it doesn't work it is hard to ignore the unanimous chorus of opinion= that it is a sound planning tool.
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Sent from my iPhone
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On Aug 19, 2017, at 7:44 AM, jeffrey E. <jeevacation@gmail.com<mailto:jee=acation@gmail.com» wrote:
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what is an apollo flight . ? when will we have the proforma ? the=gift tax paid but still fraud fable is just that . cant be found be=ause it doesnt exist. you are getting childish advice and data. ? sor=y. I was very clear with leon that you need a senior tax advisor . per=on. Joe V is not it. you have bookkeepers, accountants and enad = compliance. you going around to others to see how they work is in my=opinion the height of silliness. I consider you tthe best thing that =appened to elysium . and have been quite vocal about it. hire the best =eople . they cost money. This biz is leons most important asset that h= will leave to his kids.. It will be responsbile for a whole host of fam=ly, estate. operating issues. .
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i have not gottten involved in the documentation, of what is there . =nd its acccesibility. i would guess pretty good now. For ex, my =isccusions with other clients are a give and take, of laws mecahnisms.=tactics strategys.. audit prep. . case law.. a joint composition of=high level planning . reporting. analyisis, alternatives. hearing=about an article that your guy might have read in his dentitst office. th=t turns out to be bogus. is emblematic of the office. I am confient tha= you will grow into the job, . re clats I only asked if any of your s= called advisors have actually done one so they understand its true and =pracitcal pitfalls. your response that the art will be sold quickly. =and that there is a chapter in lerners book about it, the same book that =eon relied on to his detriment before. ( 1031 ) . was suprising, . if =he art is to be sold quickly ( not sure leon would sign on. ), DO it =efore he dies. not after. art delays the closing of the estate. le=n is the "BEST seller. , know the market etc. gains can be dealt with =
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I real tax advisor should demand at least lm per year. up to 3 . al= the big firms have a mandatory retirement at age 60. high level peopl= all on the street. my friends biz that only grosses 60 m just hired =ne for a million. guys that have hand filled out PERSONAL tax returns =TRUST returns . planned strategies years in advance. . Audit experienc= preferable large case. . some tax court experience helpful. . fille= out estate tax docs ( VERY IMPORTANT
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On Sat, Aug 19, 2017 at 7:20 AM, Barry J. Cohen <bcohen@apollolp.com<mail=o:bcohen@apollolp.com» wrote: > Some trips for Apollo are not 135 compliant due to minor issues of crew r=st or otherwise. So occasionally we have to fly Part 91 on Apollo flights.= Hard to do without Apollo being operator.
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Sent from my iPhone » On Aug 18, 2017, at 10:57 PM, Jeffrey Epstein <jeevacation@gmail.com<mai=to:jeevacation@gmail.com» wrote: » Apollo? >» On Aug 18, 2017, at 10:56 PM, Barry J. Cohen < wrote: >» >» We are factoring this into our structure recommendations. Lots of con=traints. Apollo doesn't want to be an owner or an operator. Makes 91 opera=ions for Apollo tricky. >» >» Sent from my iPhone >» >» On Aug 18, 2017, at 8:23 PM, jeffrey E. <jeevacation@gmail.commailto:j=evacation@gmail.com<mailto:jeevacation@gmailcom<mailto:jeevacation@gmail= corn>» wrote: >» >» ex >» Forwarded message >» From: Melanie Spinella >» >» >» Date: Thu, May 21, 2015 at 2:54 PM >» Subject: Plane >» To: "jeffrey E." >» sieevacation@gmail.commailto:jeevacation@gmail.com<m=ilto:jeevacat >» >» >» >» Jeffrey — Leon asked me to ask you. Debra is going to Chicago May >» 30=h — back and forth the same day. Here is the response from Jet >» >» Hi Melanie,
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»
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» For May 30th with the 12pm departure out of Teterboro and 11pm departur= out of Chicago the duty day is at 15hrs18min. For 135 trips crew cannot e=ceed 14hr duty day. If you wish to operate this flight as 135 we must do
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a=crew swap in Chicago. If we were to operate this fight as 91 with a Chief =ilot approval we could extended the duty day to 16hrs. Please let me know =ow you wish to proceed.¶
»
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» Can we switch to 91— Here is what they said about the difference:
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»
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»
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» When operation 91 the owner has operation control and we have a little =it of flexibility with extending the duty day as long the chief pilot appr=ves it.
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» When operation 135 its consider business and the rules are a lot strict=r. We are not able to extend the duty day. Two pilots can only be on duty =p to 14hrs and no more than 10hrs of flight time. >» Thank you!
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