EPSTEIN
page 2 / 391 . OCR, unverified
or to any other tins mile' information contained herein We assume no nasponsiN lily to advise the recipients of this document with regard to changes in our
views.
No assurance can be given that any investment described herein would yield favorable investment results or that the invostmoril objectives will he achieved.
Any 5(CUI-1116S or financial instruments presented heron are not insured by the Federal Deposit insurance Corporation r DIC"1 unless specifically
noted, aril are not guaranteed by o r obligations of Deetscire Bank AG or its affiliates. We or et, affilates or persons associated with its may act upon
or use nuitnrial in this report pricer to pubication. DR may engage in transactions in a manner inamsistent with the views discussed herein. Opinions
iugressed herein may differ from the opinions expressed by deprtrnentt, or other divisions or affiliates of Deutsche Bank. This document may not be
reproduced or a rculatecl without our wntten authority. I he manner 01 circulation and distribution of this docoament may be restncted by law or mutation
in coda in countries Thisdocument is not directed to. or intended for data buten to or use by. any person or entity who is a citizen or Welded of or located
ire any locality, slat'', minty orother jurisdiction, including the United States, when, surly distribution, publication. availability or use would be contrary to
Pr..' or regulation ter which would subs:cr. Deutsche Bank to any wistration or licensing requirement within StiGli jurisdiction not currently met within such
jursd€ction Persons into whose possession this doctiment may comeare required to inform themselves of, and to observe, such restrictions.
Past performance IS 110 guarantee of future results, nothing contained herein shall constitute any representation or warranty as to future performance.
Further information is available upon investors request All third party data (such as MSCI. S&P & Bloomberg) are copyrighted by and proprietary to the
provides
Additional information for wealth management clients
tor investors in the United States. Wealth-management services are offered through Deutsche Bank trust company Amelia-3S (member FDIC) and Deutsche
Bank See unties Inc. Invenda)r IINRit, Nrist,SIPCI, a registered brckereleiaker aivJ registered investment adviser that whop oonduCIS investment
banking and mcuritics activities in the Unitcd States, Deutsche Bank has published this document in good faith. This document has been prepared without
CTOdi:grin:WI of lid+ nvedriviii needs., obis:fives cr finantia I circiunslanOst; of any investor. Before making an investment decision. inveStOtS need
consider, with or without taw kmistantri of an invwctrnw I adviser, whether the investments and strategies described or pro-vided by Deutsche Bank. are
OpprOffratt1e, In lightof their partir,ultir investment newls, tiN
tives and financial circumstances Furthermore Maidocument is for informationfdiscusmon
pitposx only and dote not constitute an offer. recommendatain cr soleotation to conclude a transaction and is net investment advice.
•
Deutsche Bank AG is authenawl under Gemmel Banking Law (competent authority: European Cantnil Bank and the Satin. Germany's Federal Financial Supervisory
AiiitiNbrittd arid by the Prudential Regulation Authorityarid subject to limits ! regulation by the Financial Conduct Authonty and Prudential Regulation Authority. Dotal,
bouLtheeNtantef our auttiorisaticri aryl regulation by the Prudential Rr relation Authohty, and regulation by the Financial Conduct Authority are available from us on
L"
CTiligatt Acid
& ,th,:lith FA14112V4inksfai Investment
Maiinn,r I andstrage 11.17, 03:329 Frankfurt are Main. Germany.
s•Etdia
021664 01151GIONnEW-Y/FA-At.d.1
CONFIDENTIAL — PURSUANT TO FED. R. CRIM. P. 6(e)
DB-SDNY-0117708
CONFIDENTIAL
SDNY_GM_00263892
EFTA01457971
--- SOURCE: IMAGES__0083__EFTA01457972.txt ---
METADATA_SOURCE: IMAGES0083
METADATA_FILENAME: EFTA01457972.pdf
----------------------------------------
New York treats Mom as if she were a New York resident, and her taxable estate — the $5.34 million
credit shelter trust for Dad — exceeds New York's $1 million exclusion, thereby triggering hypothetical
New York estate tax of $431,600. Since Mom's interest in the condo represents 5% of her estate, her
New York estate tax is 521,580 (5% of $431,600).
The "new" New York estate tax produces a dramatically different result in this example: New York now only
taxes non-resident decedents on their New York-situs real and tangible personal property: it also gives
residents and non-residents alike the same New York estate tax exclusion, and does not reduce a non-
resident decedent's exclusion to reflect the ratio of New York property to the decedent's overall estate. To
illustrate:
"New" New York law. Same facts as above, except that Mom dies in April 2014. Her estate owes no
New York estate tax, as the disposition to Dad qualifies for the marital deduction, which defers estate tax