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ax advisor) and diligently reviewed the history and factual circumstances with their personal accountants and the law firm of Paul, Weiss, Rifkind, Wharton & Garrison LLP. As a result o1The conclusion reached ky that review-it was determined-that the Taxpayers were-eblia_an obligation to file the International Informa
it A ployees of the intern' tax department also withAke_nrevarationsfibe tax returns of TheAll of the Foreign Entities related to BRH, other than AP Professional Holdings LP, are also owned, in part, indirectly by Apollo. The appropriate Apollo entities timely and properly filed the Forms 8865 and 8858 with respect to t
ax advisor) and diligently reviewed the history and factual circumstances with their personal accountants and the law firm of Paul, Weiss, Rifkind, Wharton & Garrison LLP. As-a-result-eaktconchtsionstached Jy that review, it-was determined-that the Taxpayers were-ebliatn obligation to file the International Informatio
ernaLlax department of Apollo have also assisted with the nrenaration of the tax returns of B1W. TheAll of the Foreign Entities, other than BRH and AP Professional Holdings LP, are also owned, in part, indirectly by Apollo. The appropriate Apollo entities timely and properly filed the Forms 8865 and 8858 with respect to t
e have approval to prepare the revised statements, and we will get those out to you asap. Thanks Brian S. Grieve I Associate Paul, Weiss, Rifkind, Wharton & Garrison LLP I www.paulweiss.com From: jeffrey E. <[email protected]> Sent: Wednesday, February 8, 2017 1:50:04 PM To: Brad Wechsler; Grieve, Brian 5; Leo
rase and think it's accurate, but we can remove it. Does the below work then from your perspective? All of the Foreign Entities, other than BRH and AP Professional Holdings LP, are owned, in part, indirectly by Apollo. The appropriate Apollo entities timely and properly filed the Forms 8865 and 8858 with respect to these F
Apollo's tax advisor) and diligently reviewed the history and factual circumstances with their accountants and the law firm of Paul, Weiss, Rifkind, Wharton & Garrison LLP. As a result of that review, it was determined that the Taxpayers were obligated to file the International Information Returns with respect to the
rations and foreign disregarded entities (the "Foreign Entities") listed on the enclosed Exhibit A. The Foreign Entities related to BRH, other than AP Professional Holdings LP, are also owned, in part, indirectly by Apollo. The appropriate Apollo entities timely and properly filed the Forms 8865 and 8858 with respect to t
Apollo's tax advisor) and diligently reviewed the history and factual circumstances with their accountants and the law firm of Paul, Weiss, Rifkind, Wharton & Garrison LLP. As a result of that review, it was determined that the Taxpayers were obligated to file the International Information Returns with respect to the
n corporations and foreign disregarded entities (the "Foreign Entities") listed on the enclosed Exhibit A. The Foreign Entities, other than BRH and AP Professional Holdings LP, are also owned, in part, indirectly by Apollo. The appropriate Apollo entities timely and properly filed the Forms 8865 and 8858 with respect to t
Apollo's tax advisor) and diligently reviewed the history and factual circumstances with their accountants and the law firm of Paul, Weiss, Rifkind, Wharton & Garrison LLP. As a result of that review, it was determined that the Taxpayers were obligated to file the International Information Returns with respect to the
rations and foreign disregarded entities (the "Foreign Entities") listed on the enclosed Exhibit A. The Foreign Entities related to BRH, other than AP Professional Holdings LP, are also owned, in part, indirectly by Apollo. The appropriate Apollo entities timely and properly filed the Forms 8865 and 8858 with respect to t
Entities connected to both Wharton & Garrison LLP and AP Professional Holdings LP
Leon Black
PERSONDebra Black
PERSON
Deloitte
ORGANIZATIONPaul, Weiss, Rifkind
ORGANIZATIONthe "Partnership"
ORGANIZATIONthe Internal Revenue Service's
ORGANIZATIONthe Foreign Entities
ORGANIZATIONTaxpayers
ORGANIZATIONForms 5471
ORGANIZATIONDelinquent International Information Return Submission Procedures
ORGANIZATIONAAA ASSOCIATES LP
ORGANIZATIONAAA GUERNSEY LIMITED
ORGANIZATIONREM-Co
ORGANIZATIONAPOLLO SOMA II ADVISORS LP
ORGANIZATIONRaich Ende Malter & Co. LLP
ORGANIZATIONAPO FC-GP
ORGANIZATIONAPOLLO ADVISORS VII
ORGANIZATIONAPOLLO PRINCIPAL HOLDINGS VIII LP
ORGANIZATIONBRH HOLDINGS GP LTD
ORGANIZATIONAPOLLO ADMINISTRATION GP LTD
ORGANIZATION