JEFFREY D. HASKELL, J.D., LL.M. (TAXATION) EXECUTIVE VICE PRESIDENT AND CHIEF LEGAL OFFICER, FOUNDATION SOURCE

EDUCATION NEW YORK UNIVERSITY SCHOOL OF LAW, New York, New York LL.M., Taxation, June 1994 Honors:

New York University Tax Law Review

BENJAMIN N. CARDOZO SCHOOL OF LAW, New York, New York J.D., magna cum laude, June 1993 Honors:

Cardozo Law Review

BAR MEMBERSHIP New York State Bar and New Jersey State Bar

FOUNDATION SOURCE, Fairfield, CT Tax Counsel, August 2000 to October 2001 Senior Vice President, Tax & Legal Affairs, October 2001 to November 2008 Executive Vice President, Tax & Legal Affairs, November 2008 to December 2009 Chief Legal Officer, December 2009 to Present Provide guidance to a team of attorneys, accountants, and support professionals who provide tax reporting services to the company’s foundation clients and support to their advisors on a range of issues including program- and mission-related investments, grants to individuals, expenditure responsibility grants, equivalency determinations, scholarship and award programs, set-aside projects, return preparation, and compliance with self-dealing, minimum distribution requirement, excess business holdings, jeopardizing investment, and taxable expenditure rules. Meet with foundation clients to provide compliance and programmatic guidance regarding charitable programs. Designed standard corporate structure and administrative policies for foundations administered by Foundation Source, including conflict-of-interest, travel, document retention, expense reimbursement and investment policies, ensuring compliance with Internal Revenue Code Sections 4940 through 4946, et seq., and the Patriot Act. Established protocol for making short-term emergency assistance, medical distress, and hardship assistance grants to needy individuals. Designed mortgage assistance program for making program-related investments in the form of loans to individuals in severe financial distress.

KRONISH LIEB WEINER & HELLMAN LLP, New York, New York Trusts & Estates Associate, March 2000 to August 2000 Researched and drafted memorandum regarding the application of Internal Revenue Code Section 2701 to the proposed recapitalization of a closely-held corporation. Researched case law and technical advice memoranda regarding the application of Internal Revenue Code Section 2703 to family limited partnerships. Prepared interrelated computations to determine an estate’s outstanding Federal and New York State estate tax liability pursuant to Internal Revenue Code Section 6166 in order to amend the estate’s estate tax returns. Compiled and reviewed documents

JEFFREY D. HASKELL in preparation for a Federal estate tax audit and subsequently met and negotiated with examiner. Drafted Wills, IRS Trusts, Trusts for grandchildren, and Life Insurance Trusts.

OLSHAN GRUNDMAN FROME ROSENZWEIG & WOLOSKY LLP, New York, New York Tax Associate/ Trusts & Estates, July 1997 to March 2000 Prepared request for and obtained a favorable private letter ruling in connection with an Internal Revenue Code Section 355 “split-off.” Drafted like-kind exchange documents and modified contracts of sale in connection with deferred exchanges and coordinated all tax aspects of the closings of the relinquished and replacement properties. Performed Internal Revenue Code Section 382 analyses to determine maximum amount of stock that could be purchased without incurring adverse tax consequences. Reviewed and modified incentive stock plans. Participated in tax litigation in the Tax Court and the United States Court of Appeals regarding the liability of an “innocent spouse,” the reasonableness of the amount of compensation paid to corporate executives, and the deductibility of certain expenses incurred by a corporation. Researched various merger, tax-free reorganization, stock redemption, tax-free stock dividend and other corporate tax issues. Researched issues pertaining to the imposition of cancellation of indebtedness income and the conversion, recharacterization and reconversion of assets transferred between a traditional individual retirement account and a Roth individual retirement account. Drafted Wills, Life Insurance Trusts, Qualified Personal Residence Trust, Health Care Proxies, Living Wills, Durable Powers of Attorney and related materials. Engaged in extensive client contact regarding the marshaling and distribution of estate assets. Prepared and submitted Federal and New York State estate and gift tax returns. Prepared and offered necessary documents to the Surrogate’s Court in connection with the probate of Wills, the administration of estates, and renunciations of interest.

SOLOMON AND WEINBERG LLP, New York, New York Real Estate Associate, August 1996 to July 1997 Participated in negotiations, due diligence, preparation of operative loan documents for refinancing, the acquisition of loan portfolios, and construction loans for shopping centers, office buildings and tracts of raw land. Drafted corporate resolutions and partnership consents authorizing various real property acquisitions, mergers, loans and pledges of company stock or partnership interests, as applicable. Prepared and reviewed promissory notes, mortgages, loan agreements, hazardous waste indemnities, leases, uniform commercial code financing statements, and corporation, partnership and limited liability company pledge agreements.

COOPERS & LYBRAND, L.L.P., New York, New York Tax Associate, Business Tax Planning Group, October 1994 to August 1996 Researched and drafted memoranda regarding a variety of Federal and international tax issues including: C corporation conversion to an LLC, barter transactions, debt-versus-equity issues, taxability of reorganization plans, multiple-party like-kind exchanges, original issue discount, below-market loans, partnership formation and termination issues, limitations on deductibility of interest payments to related foreign parties and whether such income was United States-source income effectively connected with a United States trade or business. Corresponded with the Internal Revenue Service and participated in negotiations on behalf of client pursuant to an Internal Revenue Service audit. Participated in several research and experimentation tax credit studies for leading pharmaceutical, insurance, finance, tobacco and telecommunication companies.

JEFFREY D. HASKELL ACADEMIC ACTIVITIES BARUCH COLLEGE/ THE CITY UNIVERSITY OF NEW YORK, New York, New York Adjunct Lecturer, 1998 and 1999 Introduction to Corporate Taxation, Part II. Prepared and delivered lectures and drafted midterm and final examinations for graduate students, covering “spin-offs,” tax-free reorganizations, taxable corporate acquisitions, liquidations, redemptions, tax-free stock dividends and related subjects. PUBLICATIONS 

Jeffrey D. Haskell & Amanda Adams, The Death of Sudden Tipping, 25 TAXATION OF EXEMPTS 43 (September/October 2013) (analyzing updated regulations eliminating the special provision known as the ‘tipping rules’ and the resulting impact on private foundations)

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Jeffrey D. Haskell, Private Equity in a Private Foundation: Tips for the Investor, 39 ESTATE PLANNING 22 (September 2012) (analyzing the application of the excess business holdings rules to private foundations that invest in private equity)

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Jeffrey D. Haskell & Page Snow, Grant Making Isn’t the Only Way, 149 TRUSTS & ESTATES 35 (August 2010) (exploring alternatives to traditional grantmaking, including program-related investments, grants to individuals, and direct charitable activities)

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Jeffrey D. Haskell, Special Considerations for Private Foundation Investment Accounts, 24 INVESTMENTS & WEALTH MONITOR 14 (March/April 2009) (summarizing the benefits conferred by private foundations and the basic rules by which they are governed)

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Jeffrey D. Haskell & Amanda Adams, Transfers Between Private Foundations, 146 TRUSTS & ESTATES 35 (July 2007) (providing a tax compliance and reporting guide for asset transfers between private foundations)

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David L. Nelson & Jeffrey D. Haskell, Flaws in Revised Section 4940, 18 TAXATION OF EXEMPTS 239 (March/April 2007) (discussing ambiguities in certain provisions of the Pension Protection Act of 2006)

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Jeffrey D. Haskell, Ten Common Foundation Mistakes, 143 TRUSTS & ESTATES 38 (April 2004) (reviewing the most common compliance mistakes made by private foundations)

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Jeffrey D. Haskell, Is it Really a Public Charity?, 143 TRUSTS & ESTATES 51 (December 2004) (discussing the need for a private foundation to research the tax status of potential grantees to avoid penalties)

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Jeffrey D. Haskell, When Axioms Collide, 15 CARDOZO LAW REV. 817 (1993) (relating to the reformation of a will)

JEFFREY D. HASKELL CONTRIBUTING AUTHOR 

Jody Blazek, TAX PLANNING AND COMPLIANCE FOR TAX-EXEMPT ORGANIZATIONS (4th ed. 2004; 5th ed. 2012)

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Jody Blazek, IRS FORM 1023 TAX PREPARATION GUIDE (1st ed. 2005)

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D. L. Nelson, The Tax Consequences of Passive Offshore Investments, 17 TAXATION OF EXEMPTS 152 (January/February 2006) (discussing the tax treatment of offshore investments)

SPEAKING ENGAGEMENTS 

Excess Business Holdings Primer and Beyond, Private Foundation Summit, Foxmoor (05-23-13)

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Self-Dealing Case Studies, Private Foundation Summit, Foxmoor, co-presented with Jody Blazek & Jane Searing (05-23-13)

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Practical Considerations Surrounding Private Foundations, New York State Society of CPAs, co-presented with Jody Blazek (12-12-12)

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Practical Considerations Surrounding Private Foundations, Exempt Organizations Conference, New York State Society of CPAs, co-presented with Jody Blazek (12-12-12)

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Not Your Grandfather’s Foundation, Boston Bar Association, co-presented with Charles Fayerweather (02-28-12)

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Private Equity in a Private Foundation: The Excess Business Holdings Rules, Breakfast Meeting, Heckerling Institute on Tax Planning (01-06-12)

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Alternate Modes of Giving, Breakfast Meeting, Heckerling Institute on Estate Planning (01-12-11)

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Hot Private Foundation Topics, Western Conference on Tax Exempt Organizations, co-presented with Michael Berry (11-09-10)

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Private Foundation Case Studies, Private Foundation Summit, PESI, co-presented with Jody Blazek & Jane Searing (10-21-10)

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What Every Foundation Should Know About Compliance, New Jersey Institute of Continuing Legal Education (06-09-10)

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Private Foundations and Program Related Investments, Chicago Social Venture Forum, University of Chicago Booth School of Business (04-22-10)

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Advanced Tax Planning Strategies: What is an L3C?, Breakfast Meeting, Heckerling Institute on Estate Planning (01-26-10)

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Advanced Tax Planning Strategies for Private Foundations, 2010 Nonprofit Organizations Institute, The University of Texas School of Law (01-13-10)

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10 Rules Every Fiduciary Should Know About Governance and Compliance of Private Charitable Foundations, Hawaii Tax Institute (10-20-09)

JEFFREY D. HASKELL 

Private Foundation Case Studies, Private Foundation Summit, PESI, co-presented with Jody Blazek & Jane Searing (09-17-09)

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Everything You Need to Know About Private Foundations, Stockton Estate Planning Council (1113-07)

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Provisions of Pension Protection Act of 2006 Relating to Private Foundations, Bank of New York Luncheon (06-19-07)

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Legal Considerations for Establishing and Administering a Private Foundation, Karr Barth Associates Inc. Seminar (06-07-07)

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Provisions of Pension Protection Act of 2006 Relating to Supporting Organizations, Association of the Bar of the City of New York (03-16-07)

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Pension Protection Act of 2006: Grants from Private Foundations to Supporting Organizations, Columbus, Ohio Philanthropy Forum (11-28-06)

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Private Foundations and the Pension Protection Act of 2006, Boston Trust & Estate Attorney Luncheon (11-21-06)

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Pension Protection Act of 2006: Grants from Private Foundations to Supporting Organizations, Philadelphia Trust & Estate Attorney Luncheon (10-19-06)

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Pension Protection Act of 2006: Grants from Private Foundations to Supporting Organizations, Rocky Mountain Estate Planning Council (10-04-06)

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Private Foundations: Grants to Individuals & Program Related Investments, Association of the Bar of the City of New York (06-15-05)

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Tax Considerations of Private Foundations, Estate Planning Council of New Jersey (11-17-04)

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Giving to Individuals from a Foundation’s Perspective, Regional Bar Association Seminar (0615-04)

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What Every Private Foundation Should Know About Compliance, Delaware Valley Grantmakers (04-15-04)

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Private Foundation Overview of Chapter 42 and Primer, Regional Bar Association Seminar (1016-02)