From: Halperin, Alan S < Sent: Saturday, February 20, 2016 10:57 PM To: jeffrey E. Subject: Re: Before contribution to charity, a principal can exchange AOG units for AGM =hares in a tax free exchange. After the contribution, charity can sell.=Under current TRA , there is no TRA payments associated with the foregoing=steps. Alan Alan S. Hal erin I Partner Paul, Weiss, Rifkind, Wharton & Garrison =LP New York,&=bsp;NY 10019-6064 (Direct Phone) I Direct Fax) I www.paulweiss.com From: Jeffrey E. Sent: Saturday, February 20, 2016 3:48 PM To: Halperin, Alan Subject: Re: tax free exchange, is that the same as donatin= the stock to charity. . if the charity sells the stock = what happends to the step up On Sat, Feb 20, 2016 at 11:25 PM, Halperin, Alan=S wrote: Under TRA, no TRA rights are triggered in connection with a tax-free exchan=e. Alan Alan S. Halperin I Partner Paul. Weiss. Rifkind Wharton & Garrison =LP New York,&=bs.;NY 10019-6064 (Direct Phone) I (Direct Fax) I www.paulweiss.com <http://wwwpaulweiss.com> From: jeffrey E. Sent: Saturday, February 20, 2016 2:04 PM To: Halperin, Alan S Subject: what happened to rowens tra when he donated the shares in =ay of 14 please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of EFTA_R1_01436568 EFTA02400751 JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation®gmail.com <mailto:jeevacation@gmail.com> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved This message is intended only fo= the use of the Addressee and may contain information that is privileged a=d confidential. If you are not the intended recipient, you are hereby noti=ied that any dissemination of this communication is strictly prohibited. If you have received this communicat=on in error, please erase all copies of the message and its attachments an= notify us immediately. please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation@gmail.com <mailto:jeevacation@gmail.com> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved date-last-viewed 0 date-received 14560O9021 flags 8590195717 gmail-label-ids 5 18 remote-id 589384 2 EFTA_R1_01436569 EFTA02400752