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I hear you. There is no blue print. I think our numbers are finally thorough and accurate. We haven't discussed it much, but technology and security have been a huge focus for me since I joined Elysium. Making slow but steady progress.

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there has been little if any proper planning for tax this year and next. this needs to be done after the program and materials are put in form

e pro em is a we wan eon to tell us what art he is interested in se=ling. I don't think he can do that. We should tell him whether we want=him to sell either his gains or his losses and why.

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barry, perfect example of what i have been trying to explain. =C2® without context the question makes little sense. =x if all is income is ordinary. selling things at a los= does nothing . however if he is getting more capital gains next year. you miight generate losses and carry them=forward or back. if we think the tax rates will change we mig=t create fictiioous gains. and use the loss but have a higher =asis for next year. if the loss in on the trust side ,=C2® it is a benefit to the future tax of the children. 4>=A0sorry to be so long winded but at least i am consistant :)

jeevacation@gmail.com

These are all things we are trying to think about. Our new internal g=y is great, but he doesn't bring solutions with him because, like you =ay, no one is quite like Leon. Since he just joined us, we're starting=certain planning work later than we would like.

EY is good but they are better at answering questions than providing proact=ve planning advice. And I am finding them a little slow.

Your derivatives financing idea is a good one. Who would be a good person t= talk to about it? Justin at JPM?

Barry J. Cohen

same idea to make sure boat sale , plane sale art sale . all pr=duce the best after tax result.

jeevacation@gmail.com

Plane sale is minor loss.

Barry J. Cohen

not necessarily . talk monday.

jeevacation@gmail.com

We never took accelerated depreciation due to lack o passive income. Unuse= depreciation has been carried forward. Basis is therefore a little high.

Barry J. Cohen

yes , I would ask that you go through and see exactly which years you=tookk what and it produce a real szable benefit. . ®=A0 form a new entity for the contract signing. have tha= entity have the right to assign.

jeevacation@gmail.com

May not be possible as documents have to be signed tomorrow (our drop dead =ate). We are not going to buy the plane in Elysium. We will assign its rig=t to buy the plane before we close.

Barry J. Cohen

I would suggest a delaware Ilc , where leon is sole member.,=A0 I dont belive in drop dead dates. and rushing usually is no= wise ( slow and thoughful . ) wire =he deposit that should be enough. airplanes are fi=icky.

jeevacation@gmail.com

They have our deposit. I don't like going past the =rop dead date because if another buyer has reached out to them at a higher=price it gives the seller an excuse to walk. We can definitely have the De=aware LLC buy the plane though.

Barry J. Cohen

im told the rolls royce buy in was 1.2 m not 2 m40=A0 and the apu 50k is that not right/

After fridays discussion

https://www.aopa.org/training-and-safety/pic-archive/=ircraft-ownership/business-justification-aircraft-expenses https://www.aopa.org/training-and-safety/pic-archive/aircraft-ow=ership/business-justification-aircraft-expenses

I suggest you focus on large issues first.. the discussi=ns re personal use of plane. parties travel. may be relevant =t the tippy tip of the margins but these answers should=C2 flow from the structure. On what form will you use the =eduction.? which business. , its structure. diffe=ent buisnesses etc.

Barry, what you will find is that there is very few answers t= be found on point as people in leons position rarely make cases to tax co=rt. exception being estate issues. . =lanes owned by farmers salesman, bankers. are usua=ly small planes. meaningless to leons issue. =A0 large biz gets are usually owned by corporations. . =C2 the facts. there are approx 400,000 planes in the =tates. out of that large number only about 13, 000 total priva=e jets. out of that class only 2000 large jets =A0 and most owned by corporations. how many people have=business of leons size . not including his art work.

You asked , me what do we do now. as=I told Brad years ago. First and foremost is accur=te numbers presented in an organized fashion. that is 8= percent of the grunt work. Once all the numbers are in shape = ie materials for the building of the financial architecture.=C2. Leons goals must be addressed and programatic . =C2 this takes hours of discussion. . next . plans are=drawn up, . modifications are made, issues of sec=regulation, tax, control, succession. mechanics. all need to b= planned and adjusted to meet the goals.

You need to recognize that there are few , very few exa=ples of the house that in leons case needs to be re built. =A0 most people with leons wealth have a serious family office=C2 with a huge stock portfolio. , not art. and of those , =ew hold dormant assets ie apollo. . Its been ten years=C2 since apollo went public. and the house

needs total reno=ation. upgrades in tech, security, and the family has c=anged all very similar to architecting a house after the chil=ren have grown and left.

please note