Morgan, Lewis B'ockius LLP- . 11i1' AvenueWashington, Disirictof Columbia 20004 Tel. 202.373.6000 Sheri A. Dillon Tax Partner William F. Nelson Tax Partner March 8, 2017 President Donald J. Trump 1600 Avenue, NW Washington, DC 20500 Re: Transactions with Russian counterparties reported on your US. federal income tax returns Dear President Trump: We, Sheri Dillon and William Nelson, have served. as tax counsel to you and The Trump. Organization continuously since: 2005. As such, we are familiar with your US. .federal income tax returns and with transactions that are reported .on your returns. In this capacity, you have asked us to review yoor returns for the past 10-years. Following such review, we hereby con?rm the following facts: As disclosed in your most recent EXecutive Branch Per30nnel Financial Disclosure Report (OGE Form 27'8e), ?led on May 16, .2016, you hold interests as the sole or principal ownei in more than 500 separate entities These entities are collectively referred to and do business as TTO. Because you operate these businesses almost exclusively through sole prop1 ietorships, -corporations, and/or partneiships, your personal federal income tax returns refleCt Income that IS earned by these entities and interest that is paid or received by these entities, as well as income that you directly earned or interest that you paid or received. With a few exceptions as detailed below?m your taxreturns do not reflect (1) any income of any type from Russian Sources, (2) any debt owed by you to Russian lenders or any interest paid by yOu or TT-O to Russian lenders, (3) any equity ?investments by Russian persons or entities in entities controlled by you or TTO, or (4) any equity or debt investments by you Or in Russian entities. The exceptions are: (1) in 2013, the. Miss Universe pageant was held in Moscow, and of the $12.2 million of fereign income that it earned that year, a substantial portion of it was. attributable to the Moscow event; (2) in 2008, Trump Properties LLC sold an estate in Florida, that it had acquired in 2005 for approximately $41 million, to a Russian billionaire fer $95 million; and (3) over the years, it is likely that TTO or third-party entities engaged in ordinary course sales of goods or services to Russians or Russian entities, such as sales rentals fees for condominiums, hotel rooms, rounds of golf, books or Trump? licensed products ties, mattresses, wine, etc.) that could have produced income attributable to. Russian sources (such income Would not have been separately identi?ed as ?Russian? in your books and records and therefore not separately reflected on your tax returns). With respect to this last exception, the amounts are immaterial. Regards, e/mtiioom Sheri A. Dillon il 1a F. Nelson Amaty Astana Beijing Boston BruSseis' Chicago Dallas Dubai Frankfurt Harrisburg Hartford Houston London LosAngeles Miami Moscow NewYork Orange County Paris Philadelphia Pittsburgh Princeton San Francisco Santa Monica Silicon Valley Tokyo Wa'shington Wilmington