To: Richard Joslin Cc: Jeffrey Epstein eevaca ion gma .com) From: Fenn, Patrick Sent Thur 2/27/2014 4:09:22 PM Subject: Re: Camp proposal and Sun Capital It's a ridiculous position, unsupported by any authority. If you read the carried interest discussion in Joint Committee reports on the Levin and Obama proposal over the last 7 years, they admit that PE carry is currently capital gain but should be taxed as ordinary income. Revisionist tax history by Camp. From: Richard Joslin Sent: Thursday, February 27, 2014 9:58 AM To: Fenn, Patrick Cc: Jeffrey Epstein Subject: Camp proposal and Sun Capital Patrick: • As you eloquently debated publicly a contrary (and in my belief correct) position on this, I note that Camp (HWM Chair) apparently believes Sun Capital is applicable to Sec 162 and that PE activity is a developer/dealer. From page 121 • A partnership (e.g., private equity fund) that is in the business of raising capital, investing in other businesses, developing such businesses, and ultimately selling them, is in the trade or business of selling businesses. The businesses bought and sold by the partnership are its inventory. IRS Circular 230 Notice Requirement: This communication is not given in the form of a covered opinion, within the meaning of Circular 230 issued by the United States Secretary of the Treasury. Thus, we are required to inform you that you cannot rely upon any tax advice contained in this communication for the purpose of avoiding United States federal tax penalties. In addition, any tax advice contained in this communication may not be used to promote, market or recommend a transaction to another party. The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. EFTA_R1_00381919 EFTA01931024