Dante - kids' trusts

Hi Jeffrey,

With respect to the purchase of the Dante by the kid=' trusts (Yggdrasil Trust, Rollo Tomasi Trust, Tron Trust and Gandal= Trust), I just mentioned to Brad that each child is the grantor of his or=her respective trust, so if the trusts purchase the Dante and then contribute their interests in the Dante to AP =arrows LP in exchange for limited partnership interests, AP Narrows will b= treated as a partnership for income tax purposes (not a pass-through enti=y).

I'm not sure where you and Leon came out on th= question of whether you would prefer for AP Narrows to be a disregarded e=tity for income tax purposes or taxed as a partnership, so I just wanted t= flag this to you.

Best,

Heather

Heather Gray

Elysium Management LLC

445 Park Avenue

Suite 1401

New York, New York 10022

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