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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
their tax advisors, but-instead-is-relled-inte-the-tax-reperting-ef-BRI4. As a result, neither the Taxpayers nor their professional accountants at REM-Co were aware that these filings were required and, in any case, they were not provided the information necessary to have properly eempletecomnleted 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
or their tax advisors, but instead is rolled into the tax reporting of BRH. As a result, neither the Taxpayers nor their professional accountants at REM-Co were aware that these filings were required and, in any case, they were not provided the information necessary to EFTA00584477 properly complete
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
he Taxpayers or their tax advisors, but instead is rolled into the tax reporting of BRH. As a result, neither the Taxpayers nor their accountants at REM-Co were aware that any other International Information Return filings were required and, in any case, they were not provided the information necessary
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
or their tax advisors, but instead is rolled into the tax reporting of BRH. As a result, neither the Taxpayers nor their professional accountants at REM-Co were aware that these filings were required and, in any case, they were not provided the information necessary to EFTA00584470 properly complete
Entities connected to both Wharton & Garrison LLP and REM-Co
Leon Black
PERSON
Deloitte
ORGANIZATIONDebra Black
PERSONPaul, Weiss, Rifkind
ORGANIZATIONAP Professional Holdings LP
ORGANIZATIONthe Foreign Entities
ORGANIZATIONthe Internal Revenue Service's
ORGANIZATIONTaxpayers
ORGANIZATIONthe "Partnership"
ORGANIZATIONForms 5471
ORGANIZATIONRaich Ende Malter & Co. LLP
ORGANIZATIONAPOLLO EPF CAPITAL MANAGEMENT LIMITED
ORGANIZATIONAPO FC-GP
ORGANIZATIONDelinquent International Information Return Submission Procedures
ORGANIZATIONAPOLLO ADVISORS VII
ORGANIZATIONAPOLLO PRINCIPAL HOLDINGS VIII LP
ORGANIZATIONAAA ASSOCIATES LP
ORGANIZATIONAAA GUERNSEY LIMITED
ORGANIZATIONADIC LIFE ADVISORS LP
ORGANIZATIONAPOLLO SOMA II ADVISORS LP
ORGANIZATION