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payable, if any, as a result of the receipt of such Forfeited Interests and Heritage Points, calculated based on the maximum combined U.S. federal, New York State and New York City tax rate applicable to individuals. Transfers pursuant to this Section 4.1(d) shall not increase a Principal Group's number of Tr
ered into the Principals Contribution Agreement (as defined herein) whereby the Principals and their Groups contributed certain equity interests in the Apollo Operating Group to Intermediate Holdings (as defined herein) and sold certain equity interests in the Apollo Operating Group to APO Corp. and APO LLC (each as defi
payable, if any, as a result of the receipt of such Forfeited Interests and Heritage Points, calculated based on the maximum combined U.S. federal, New York State and New York City tax rate applicable to individuals. Transfers pursuant to this Section 4.1(d) shall not increase a Principal Group's number of Tr
tered into the Principals Contribution Agreement (as defined herein) whereby the Principals and their Groups contributed certain equity interests in the Apollo Operating Group to Intermediate Holdings (as defined herein) and sold certain equity interests in the Apollo Operating Group to APO Corp. and APO LLC (each as defi
quired to pay Taxes payable, if any, as a result of the receipt of such forfeited interests, calculated based on the maximum combined U.S. federal, New York State and New York City tax rate applicable to individuals. Transfers pursuant to this Section 4.2 shall not increase a Principal Group's number of Trans
ered into the Principals Contribution Agreement (as defined herein) whereby the Principals and their Groups contributed certain equity interests in the Apollo Operating Group to Intermediate Holdings (as defined herein) and sold certain equity interests in the Apollo Operating Group to APO Corp. and APO LLC (each as defi
Entities connected to both New York State and the Apollo Operating Group

United States
LOCATIONLeon Black
PERSON
Samantha Power
PERSONthe Southern District
LOCATIONthe State of New York
LOCATION
United Kingdom
LOCATIONWeiss
PERSONthe District of Columbia
LOCATION
Eric Holder
PERSONCayman
LOCATIONLevin
PERSON
Exchange
ORGANIZATION
Apollo Global Management
ORGANIZATION
Holdings
ORGANIZATION
the United States District Court
ORGANIZATIONFund IV
ORGANIZATIONBRH Holdings GP
ORGANIZATIONJohn J. Suydam
PERSON
Cayman Islands
LOCATIONApollo Management Holdings
ORGANIZATION