<table><tr><th>From:</th><th>jeffrey E. &lt;jeevacation@gmail.com&gt;</th></tr><tr><td>Sent:</td><td>Tuesday, September 20, 2016 7:11 PM</td></tr><tr><td>To:</td><td>William Blum</td></tr><tr><td>Subject:</td><td>Re: legislation</td></tr></table>

lets try to talk tomorw

When do you want to discus= your list of trust—related points below or any other aspects of t=e bill? Most of these points are already covered except principal an= income and decanting. I have already drafted and added decanting pr=visions for the next draft, which I want to circulate in the next day or t=o.

I am also thinking =f adding the Uniform Principal and Income Act. The VI has never had this l=gislation and nearly every other U.S. jurisdiction does have it.=/u>

I have also drafted a provision to elim=nate the "Obama care tax" (formally known as the Net Inves=ment Income Tax) with respect to USVI source interest and dividends in the=future as well as some provisions to assist in enforcement of the tax with=respect to past years (the tax started in 2013). Apparently, a lot o= taxpayers have not been paying it arguing that it is not mirrored. = don't know if you have been paying this tax but in our view it is=clearly applicable. But this also brings up again the issue of an eq=ivalent of PR Act 22 to eliminate all taxes on VI source capital gains (at=least on personal property) and other passive income to the extent allowed=by the IRC. In PR this only applies to newcomers. We need to t=lk about this.

Bill

William Blum | Partner<=>

40 Wall Street, 35th floor
New York, N= 10005

Tel

██████████

Fax

=/td>██████████<tel:██████████> =/u>

Email

<mailto:

From: jeffrey E. [mai=to:jeevacation@=mail.com <mailto:jeevacation@gmail.com> I
Sent: Thursday, September 15, 2016 6:18 PM
=o: William Blum
Subject:

1.=C2 Quie= Trusts vs. Trusts with obligation of Trustee to disclose to beneficiaries=

2. <=span>Divided or Directed Trusts.<=>

4. =A0 Decanting.=/p>

5. Reformation and modification.

- 6.=C2 Dyna=ty Trusts.

7.=span style="font-size:7.0pt;color:#1f497d"> =A0 Self-settled asset protection t=usts.

8. =C2 Income and princ=pal division.

<= class="MsoNormal">

please not=

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

=div dir="ltr"> please note
=div>The information contained in this communication is confidential, ma= be attorney-client privileged, may constitute inside information, and =s intended only for the use of the addressee. It is the property of =EE Unauthorized use, disclosure or copying of this communication or =ny part thereof is strictly prohibited and may be unlawful. If you have=received this communication in error, please notify us immediately byreturn e-mail or by e-mail to jeevacation@gmail.com <mailto:jeevacation@gmail.com> , and destroy this communicatio= and all copies thereof, including all attachments. copyright -all righ=s reserved