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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
al income tax purposes (should be distinguishable from thepreferred equity that was reviewed and held to be debt for federal income tax purposes in Castle Harbor 3 104773603 14.1,0 EFTA_R1_00451004 EFTA01969638 AGSH&F DISCUSSION DRAFT JUNE 19.2013 Calculation of thc value of thc preferred interests hel
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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
l income tax purposes (should be distinguishable from the preferred equity that was reviewed and held to be debt for federal income tax purposes in Castle Harbor . 3 104773603 v10 EFTA00582849
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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
fectively subject to estate tax. 7. Impact on the tax effects if the preferred interests were treated as debt for federal income tax purposes (ala Castle Harbor decision). 8. Would the tax effects on basis/step up at death/estate tax considerations/non-tax considerations be the same if the SPV/principals ac
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Entities connected to both Tufts and Castle Harbor
