<table><tr><th>From:</th><th>Brad Wechsler</th></tr><tr><td>Sent:</td><td>Wednesday, October 12, 2016 9:47 PM</td></tr><tr><td>To:</td><td>Richard Joslin; Jeffrey Epstein</td></tr><tr><td>Cc:</td><td>John Castrucci; Tom Turrin</td></tr><tr><td>Subject:</td><td>Re: foreign tax credit</td></tr></table>

Hi rich•as I mentioned to john earlier this is good news; I will want to di=cuss and understand in more detail tomorrow. B Sent from my Verizon Wireless BlackBerry

From: Richard Joslin
Date: Wed, 12 Oct 2016 21:26:44 +0000
To: jeffrey <u>Neevacation mail.com>• Brad</u> Wechsler
Cc: John Castrucci ; Thomas Turrin=
Subject: FW: foreign tax credit

Good news re foreign t=x credits — general category credits from 2015 should be carried over to=2016 (no carryback to 2014). One caveat and I will not put into emai= (pls call to discuss)

Foreign tax credits. 1 year carryback; 10 year carryforward. Credits arise from "general category " income (management=fees) or from "passive category" income (interest/ dividends).

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In 2012, all carry forwa=d and current year foreign tax credits were utilized.

General category credit =arryback of $456,067 from 2013 (regular tax) and $528,706 (al= min) would have been absorbed into 2012 for regular and alt min purposes.=o:p>

General category credit =arryback of $490,837 from 2014 (regular tax) and $196,6=1(alt min) would not be carried back to 2013 and would be carried over to 2015= (no capacity to absorb in 2013 for regular and alt min p=rposes).

All passive category cre=its were utilized in 2013 and 2014.

Any unused passive category credit of $143,307 from 2015 would be carried back and absorbed in 2014 (lost if not c=rried back)

Unused general category =redit of $1,881,188 from 2015 would not be carried back to 2014 and would be carried over to 2016 &n=sp; Carryover credit from 2014 would be carried over to 2016.40:p>

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Regular tax (2012):

Alt min (2012):

Regular tax( 2013)

Regular tax (2013) – general category – full use=(no capacity to absorb carryback)

Regular tax (2013) – passive category (capacity to=absorb carryback passive category credit)

Alt min (2013) – full use of general category cred=t

AMT 2013 ( capacity to absorb carryback fo passive c=tegory tax credits)

Regular tax 2014

General category bucket — fully utilized NO capaci=y to absorb carry back

Regular tax 2014

Passive bucket (regular) fully use with capacity to =bsorb carryback credit

AMT 2014

GENERAL CATEGORY: Capacity to absorb general categor= credit of $196,641

AMT 2014: PASSIVE CATEGORY capacity to absorb unused=passive category credits = 1,

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