EFTA02563267

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From: Sent: To: Cc: Subject: Eileen Alexanderson < > Saturday, November 17, 2012 4:44 PM Re: [WARNING: MESSAGE ENCRYPTED)FW: Leon Black form 709 Tom will answer but he definitely used some of the $1.7 this year. From: McCaffrey, Carlyn Sent: Saturday, November 17, 2012 07:45 AM To: >; Eileen Alexanderson Cc: Kirschner, Elyse < >; Jeffrey Epstein <[email protected]> Subject: [WARNING: MESSAGE ENCRYPTEDJFW: Leon Black-form 709 Leon's 709 shows that he still had $1.74 million of gift tax credit left at the beginning of 2012. Can one of you check to see if he's made any taxable gifts during 2012 so that we know how much he has left. If he hasn't made any further gifts, the simplest approach is probably to have him make a gift to his 1997 GST exempt trust. Carlyn S. McCaffrey I Partner McDermott Will & Emery LLP I From: Kirschner, Elyse Sent: Friday, November 16, 2012 5:58 PM To: McCaffrey, Carlyn Subject: FW: Leon Black - form 709 New York, NY 10173 > J www.mwe.com <http://www.mwe.com> Here's Leon's 2011 gift tax return (the code to open the return is 10018). Leon used $1.0 million of his gift tax credit through 2010. In 2011, he made taxable gifts of $2.374 million. So, he still has about $1.74 million of his credit left. EFTA_R1_01725858 EFTA02563267 He used $3.5 million of his GST exemption. He should just make a gift of $1.5 million to his 1997 GST exempt trust. Elyse G. Kirschner I Partner McDermott Will & Emery LLP I New