Epstein Secrets

e discussed at great length the net tax effects to the Founders of guaranteeing the debt, essentially deferral of tax on what we referred to as the "Tufts gain" -- the gain that a Founder recognizes on an exchange of AOG Units for AGM Class A Shares as a result of his current negative capital account

uaranteeing the debt, essentially deferral of tax on what we referred to as the "Tufts gain" -- the gain that a Founder recognizes on an exchange of AOG Units for AGM Class A Shares as a result of his current negative capital account in AMH, offset by the impact of the deferral of such gain on the timing a

to the decedent's Principal's estate pursuant to the existing TRA. Overall Effect The overall effect of this plan should be the elimination of any Tufts gain [(including upon an interim exchange of AOG Units for AGM Class A Shares, except for any non-recourse debt remaining as a result of the interg

e existing TRA. Overall Effect The overall effect of this plan should be the elimination of any Tufts gain [(including upon an interim exchange of AOG Units for AGM Class A Shares, except for any non-recourse debt remaining as a result of the intergrettp-lieldintragroup-held AMH debt not repaid under thi

ed distribution of Mr. Black's share of the non-recourse liabilities of AMH Holdings and (ii) the recognition of gain (what we have referred to as "Tufts gain") to the extent such deemed distribution exceeds Mr. Black's adjusted tax basis in AMH Holdings. However, while not free from doubt, such deem

ontinuing Principals." Exchanges to Pay Taxes After his death or Disability, in the event an Apollo professional other than a Principal forfeits AOG Units or other economic interests, and they are distributed to Principals and ' The document summaries contained herein are intended to address the most s

04773603 v10 EFTA00582848 AGSH&F DISCUSSION DRAFT JUNE 19, 2013 Overall Effect The overall effect of this plan should be the elimination of any Tufts gain [(including upon an interim exchange of AOG Units for AGM Class A Shares, except for any non-recourse debt remaining as a result of the intrag

JUNE 19, 2013 Overall Effect The overall effect of this plan should be the elimination of any Tufts gain [(including upon an interim exchange of AOG Units for AGM Class A Shares, except for any non-recourse debt remaining as a result of the intragroup-held AMH debt not repaid under this plan and alloca

principal either during his life or at death pursuant to his will. Overall Effect The overall effect of this plan should be the elimination of any Tufts gain [(including upon an interim exchange of AOG Units for AGM Class A Shares, except for any non-recourse debt remaining as a result of the intrag

t to his will. Overall Effect The overall effect of this plan should be the elimination of any Tufts gain [(including upon an interim exchange of AOG Units for AGM Class A Shares, except for any non-recourse debt remaining as a result of the intragroup-held AMH debt not repaid under this plan and alloca