From: Halperin, Alan S <
Sent: Saturday, February 20, 2016 10:57 PM
To: jeffrey E.
Subject: Re:

Before contribution to charity, a principal can exchange AOG units for AGM =hares in a tax free exchange. After the contribution, charity can sell.=Under current TRA , there is no TRA payments associated with the foregoing=steps. Alan Alan S. Hal erin I Partner Paul, Weiss, Rifkind, Wharton & Garrison =LP

New York,&=bsp;NY 10019-6064

(Direct Phone) I Direct Fax) I www.paulweiss.com

From: Jeffrey E.
Sent: Saturday, February 20, 2016 3:48 PM
To: Halperin, Alan
Subject: Re:

tax free exchange, is that the same as donatin= the stock to charity. . if the charity sells the stock = what happends to the step up

On Sat, Feb 20, 2016 at 11:25 PM, Halperin, Alan=S
wrote:

Under TRA, no TRA rights are triggered in connection with a tax-free exchan=e. Alan

Alan S. Halperin I Partner

Paul. Weiss. Rifkind <u>Wharton</u> & Garrison =LP

New York,&=bsp;NY 10019-6064

(Direct Phone) I

(Direct Fax)

www.paulweiss.com

<http://wwwpaulweiss.com>
From: jeffrey E.
Sent: Saturday, February 20, 2016 2:04 PM
To: Halperin, Alan S
Subject:

what happened to rowens tra when he donated the shares in =ay of 14

please note

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please note

The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation@gmail.com <mailto:jeevacation@gmail.com> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved

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