Re: Re:

Bill,

Hopefully, all is behind. I suggest minimal documents. very minimal. Though trust has been damaged, it still must remain the ultimate glue. I am encouraging Boris to get out his email sooner rather than later.

Larry met with Boris yesterday.? To be super cleat Boris was prepared to address what HE had done. his actions, his interactions. In that regard the tax opinion re gifts to employees that you referenced would be helpful.

I am in Santa Fe, for August if you would like to visit.. Both Jagland and Terje will be in New York sept 20-28, they would like to have very small dinner. lets set up early. ( of course Melinda can come, if you want ). Terje has his foreign minister dinner , you have been invited, ( the only non diplomat).

Happier times ahead. cell

when you have a moment lets speak. no urgency. I spoke to my IRS people , and except for deminus gifts. and small amounts given for specifically exempt reasons, any cash to an employee they tell me is compensation . no referece to market rate salary etc. If your guys could send us a code section ,and site that would be helpful. I m leaning to filing an amended return. But, details only for the phone.

what should i tell Terje?

Thanks for your help. I don’t know how to say that strongly enough.

I think we are on a good track now.

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I did check that I paid a gift tax on it. I can't send you the legal opinion for a couple of reasons but the question is simply whether it is a gift or for services rendered.

If someone has been doing the same services for the same salary which is market endorsed salary using outside HR advice and you decide to make a gift which you pay the gift tax on the presumption is in your favor.

There can't be any services rendered related to it or then it is taxable to the recipient. I will bet I am more careful about gift taxes than almost any other tax payer.

Boris didn't work for me as an employee at that time. He worked for the Foundation. His salary was set by other people without influence by me based on market standards and had stayed the same.

The facts fit exactly the situation I had had many other times before where I gave things to Microsoft employees like Netjet time and paid gift taxes on those things.

My gift of Jet time to Steve was substantial every year for over 8 years.

can we speak, ? The consensus is that it can't be a gift. facts and circumstances in addition to cash payment. if you have some authority, opinion, or at a minimum a copy of the gift tax return with all other than boris;s name redacted i can try. or we can speak with your tax attny if need be, is larry aware, eclipse etc I have not mentioned it.