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RE: 2017 1040 Draft P&C

9 messages picture_as_pdf Source PDF
J
Joseph Vinciguerra Oct 2, 2018 5:49 PM
To
Jeffrey

Hi Jeffrey,

I hope all is well. I am in the process of finalizing Leon's 2017 1040. Leon would appreciate if you did a high-level review of the draft. Please let me know your delivery preference, as it is over 1,700 pages.

Thank you.

Joe

Joseph M. Vinciguerra |

Tax Director & Tax Counsel |
Elysium Management LLC |
445 Park Avenue Suite 1401, New York, NY 10022 |
Tel. ████████████ |
███████████████████ mailto:█████████████████████

J
J Oct 2, 2018 5:51 PM
To
Joseph Vinciguerra

email

J
Joseph Vinciguerra Oct 2, 2018 8:02 PM
To
J
Cc
Barry J. CohenBrad Wechsler

Please see attached. Note, I am still working through some immaterial issues with the preparer. Let me know if you have any questions.

Password to follow.

Joe

Joseph M. Vinciguerra |

Tax Director & Tax Counsel |
Elysium Management LLC |
445 Park Avenue Suite 1401, New York, NY 10022 |
Tel. ███████████ |
███████████████ mailto:██████████████████████

J
Joseph Vinciguerra Oct 2, 2018 8:03 PM
To
'J'
Cc
Barry J. CohenBrad Wechsler

"JEE2017"

Joseph M. Vinciguerra |

Tax Director & Tax Counsel |
Elysium Management LLC |
445 Park Avenue Suite 1401, New York, NY 10022 |
Tel. █████████████ |
████████████████████ mailto:████████████████████

J
Joseph Vinciguerra Oct 5, 2018 9:03 AM
To
J
Cc
Barry J. CohenBrad Wechsler

Hi Jeffrey,

Based on travel schedules, Mrs. Black will be signing the returns on Tuesday and Leon on Wednesday. As such, if you have any comments that could change the return, please let me know, so I can incorporate them, as applicable.

Thank you.

Joe

Joseph M. Vinciguerra |
Tax Director & Tax Counsel |
Elysium Management LLC |
445 Park Avenue Suite 1401, New York, NY 10022 |
Tel. ██████████ |
████████████ mailto:██████████████

J
J Oct 5, 2018 9:25 AM
To
Melanie SpinellaJoseph VinciguerraBarry J. Cohen

? all of these issues were known for months? review income numbers flowing through 8621,? cost of good s 10 places show zero. . my fees increase phaidon loss. if leon wants. foreign taxes paid but shows no income? debra is showing an IRA deduction? did she get salary ? . need to check 965 cfc rules this year. . interest cost on approriate schedule?

more later. . landing soon.

J
Joseph Vinciguerra Oct 5, 2018 9:55 AM
To
J
Cc
Barry J. CohenBrad Wechsler

I'm not sure what issues being known for months you are referring to.

• All of the 8621 numbers are Apollo flow through figures, as reported to us on the BRH K•1and are properly reported, as income from QEF elected PFICS.

• What cost of goods sold numbers are you referring to? All reported costs of goods sold are in the proper places on either schedule C, the 8865 or the 8858s.

• We discussed your fees regarding the Phaidon loss and opted not to include them in the Phaidon transaction. Note, the amounts paid in 2017 are being deducted as investment related expenses.

• There is no net foreign income, based on the allocation of expenses and the BRH related foreign expenses. As such, we are taking the foreign taxes paid as a deduction this year (based on the carryforward). Leon is aware of this and made the decision to deduct.

• Debra does not need her own income to contribute to an IRA under the current rules, as Leon has enough wages to cover both contributions.

• 965 cfc rules have already been vetted by EY and are no applicable as we have no CFC E&P.

• The interest paid is bifurcated between schedules A and E as appropriate, and run through the 4952.

J
J Oct 6, 2018 8:33 AM
To
Joseph Vinciguerra

when i said issues i mean income items interest expense. facts needed to calculate return seperate from some possible late kls

J
Joseph Vinciguerra Oct 6, 2018 12:56 PM
To
J
Cc
Brad WechslerBarry J. Cohen

Hi Jeffrey,

All K-ls were received timely and are input into the return accordingly. Additionally, all other income and expense items are included in the draft, as I separately track each item to ensure completeness.

Please let me know if you need anything else.

Joe

Joseph M. Vinciguerra I

Tax Director & Tax Counsel
Elysium Management LLC I
445 Park Avenue Suite 1401, New York, NY 10022 I Te

1419 files from the DOJ Epstein case media release. All files are public records from justice.gov.

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