Epstein Secrets

New York Mellon will act as depositary for each of Cleargrerun and Euroclear. Clearstream has advised us that it is incorporated under the laws of Luxembourg as a professional depositary. Clearstream holds securities for its participants and facilitates the clearance and settlement of securities transacti

had not occurred. That opinion, in the case of defeasance but not covenant defeasance. must refer to and be based upon a ruling received by us from the Internal Revenue Service or published as a revenue ruling or be based upon a change in applicable federal income tax law. If we exercise our covenant defeasance option with

States), Finland, France, Germany, Greece, Gulf Co-operation Council, Hong Kong, Iceland, India, Ireland, Italy, Japan, Kingdom of the Netherlands, Luxembourg, Mexico, New Zealand, Norway, Portugal, Republic of Korea, Russian Federation, Singapore, South Africa, Spain, Sweden, Switzerland, Turkey, United

stor) If a limited partner in a partnership is not a "United States person," the partnership must withhold from such a limited partner and remit to the Internal Revenue Service taxes with respect to certain transfers of property and with respect to the limited partner's allocable share of the Fund's effectively connected t

offshore enforc=ment efforts have reached far beyond Switzerland, as evidenced by publicly=announced actions involving banking activities in India, Luxembourg, Liech=enstein, Israel and the Caribbean. BSI had more than 3,000 active United State=-related accounts after 2008, many of which it knew were not

or debit cards to many U.S. accountholders without names visible on the card itself...AO BSI not only helped U.S. clients shield the=r identity from the Internal Revenue Service (IRS). but helped them repatriate cash as well. BSI admitted that its relationship man=gers and their U.S. clients used code words in emails to gai

o the transfer agent in accordance with their respective customary procedures. Clearstream has advised us that it is incorporated under the laws of Luxembourg as a professional depositary. Clearstream holds securities for its participants and facilitates the clearance and settlement of securities transact

y may obtain a refund of any amounts withheld under the backup withholding rules that exceed your income tax liability by filing a refund claim with the Internal Revenue Service. THE PRECEDING DISCUSSION OF THE MATERIAL UNITED STATES FEDERAL INCOME TAX CONSEQUENCES IS FOR GENERAL INFORMATION PURPOSES ONLY AND IS NOT BEING

ses a broad range of transaction, financial. managerial and investment skills. We have offices in Ncw York. Los Angeles. Houston. London. Frankfurt. Luxembourg. Singapore. Hong Kong. and Mumbai. We operate our private equity. capital markets and real estate businesses in a highly integrated manner. which we

xempted limited partnership through which our managing partners and contributing partners hold their Apollo Operating Group units: ' IRS" refers to the Internal Revenue Service; "managing partners" refers to Messrs. Leon Black. Joshua Harris and Marc Rowan collectively and. when used in reference to holdings of interests in

tates: Austria, Belgium, Bulgaria. Czech Republic, Denmark, Finland, France. Germany. Hungary, Iceland, Ireland, Italy, Japan, Latvia, Lithuania, Luxembourg, Netherlands, Russia. Slovak Re- public, Slovenia. South Africa. Spain. Sweden, Tunisia, Turkey, Ukraine, and the United King- dom. Gambling income

le for closing the transaction, other than the trans- feror's agent, and (b) the transferee's agent. 5. You receive a withholding certificate from the Internal Revenue Service that excuses withholding. See Witbholdlnq Certificates, later. 6. The transferor gives you written notice that no recognition of any gain or loss

l be concluded in Kuwait. No marketing or solicitation or inducement activities are being used to offer or market interests in the Fund in Kuwait. Luxembourg Notice to Investors in Luxembourg No public offering of interests in the Fund is being made to investors resident in Luxembourg. Interests in the F

hat, although the Partnership intends to adopt positions it believes are in accord with current interpretations of the U.S. federal income tax laws, the Internal Revenue Service ("IRS") may not agree with the tax positions taken by the Partnership and that, if challenged by the IRS, the Partnership's tax positions might not

determination). "Moody's Group III Country": Any of the following countries: Austria, Belgium, Denmark, Finland, France, Iceland, Liechtenstein, Luxembourg, Norway, Spain and any country subsequently determined by Moody's to be a Moody's Group III Country (provided that the Trustee is notified in writi

e not required to make gross-up payments that cover the full amount of such withholding taxes on an after-tax basis or (ii) a final determination by the Internal Revenue Service or a court of competent jurisdiction or an opinion of nationally recognized tax counsel experienced in such matters acceptable to the Collateral Ma

h source as discussed above. Luxembourg Taxation Millennium USA and the Master Partnership have been separately advised as follows with respect to Luxembourg taxation. Classification of the Master Partnership and Millennium USA as Foreign Taxpayers. For Luxembourg tax purposes, entities which do not have

the income taxation of Millennium USA and its Partners which should be considered by a Limited Partner. Millennium USA has not sought a ruling from the Internal Revenue Service (the "Service") or any other federal, state or local agency with respect to any of the tax issues affecting Millennium USA, nor has it obtained an

h source as discussed above. Luxembourg Taxation Millennium USA and the Master Partnership have been separately advised as follows with respect to Luxembourg taxation. Classification of the Master Partnership and Millennium USA as Foreign Taxpayers. For Luxembourg tax purposes, entities which do not have

the income taxation of Millennium USA and its Partners which should be considered by a Limited Partner. Millennium USA has not sought a ruling from the Internal Revenue Service (the "Service") or any other federal, state or local agency with respect to any of the tax issues affecting Millennium USA, nor has it obtained an