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morandum, references to the "United States" or "U.S." will mean the United States of America, its territories and possessions, any state thereof and the District of Columbia. References to "S" or "Dollars" are to United States dollars and references to "E" or "Euros" are to the Euro unless the context indicates otherwis
er requirements must be met. Prospective investors should consult their own tax advisors to determine the impact, if any, such rules have on them. Personal Holding Companies. The AlphaKeys Fund through its investment in the Underlying Fund, may be deemed to own stock or securities of corporations treated as personal hold
ity taxable as a corporation for U.S. Federal income tax purposes) created or organized under the laws of the United States or any state thereof, or the District of Columbia, (iii) an estate, the income of which is subject to U.S. Federal income taxation regardless of its source, or (iv) a trust (a) the administration o
d items of income, deduction and credit of APO Asset Co., LLC will be treated as our assets, liabilities and items of income, deduction and credit. Personal Holding Companies. APO Corp. could be subject to additional U.S. Federal income tax on a portion of its income if it is determined to be a personal holding company, o
ity taxable as a corporation for U.S. Federal income tax purposes) created or organized under the laws of the United States or any state thereof, or the District of Columbia, (iii) an estate, the income of which is subject to U.S. Federal income taxation regardless of its source, or (iv) a trust (a) the administration o
d items of income, deduction and credit of APO Asset Co., LLC will be treated as our assets, liabilities and items of income, deduction and credit. Personal Holding Companies. APO Corp. could be subject to additional U.S. Federal income tax on a portion of its income if it is determined to be a personal holding company, o
Entities connected to both the District of Columbia and Personal Holding Companies

United States
LOCATIONLeon Black
PERSON
Samantha Power
PERSON
United Kingdom
LOCATION
Eric Holder
PERSONCayman
LOCATIONRegistrar
ORGANIZATION
Madrid
LOCATIONWeiss
PERSONthe New York Stock Exchange
ORGANIZATIONJoint Book-Running Managers
ORGANIZATIONWharton & Garrison LLP
ORGANIZATIONthe Foreign Investment in
ORGANIZATIONTHE U.S. FEDERAL, STATE
ORGANIZATION
Holdings
ORGANIZATION
Apollo Global Management
ORGANIZATIONGlobal Management
ORGANIZATIONthe Apollo Operating Group
ORGANIZATIONAPO Corp.'s
ORGANIZATIONAMH Holdings
ORGANIZATION