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012, which was timely paid. The Original Return, the Amended Return and the accompanying International Information Returns were all prepared by the Taxpayers' professional accountants at Raich Ende Matter & Co. LLP ("REM-Co"). Background The Taxpayers own interests in a wide variety of entities related-
nal Return. A Form 8938 was gjgg timely filed by the Taxpayers with the Original Return and is being amended today to reflect the correct number of Forms 5471 and 8865 in Part IV required to be filed by the Taxpayers as well, as adding reporting on two additional Non-BRH Related Entities. Finally, the inf
014, which was timely paid. The Original Return, the Amended Return and the accompanying International Information Returns were all prepared by the Taxpayers' professional accountants at Raich Ende Malter & Co. LLP ("REM-Co"). Background The Taxpayers own interests in a wide variety of entities relatecH
A Form 8938 was also timely filed by the Taxpayers with the Original Return and is only being amended today simply-to reflect the correct number of Forms 5471 and 8865 in Part IV required to be filed by the Taxpayers. The Taxpayers were unawarenot made aware of their obligation to file the International I
een subject to tax penalties. The Taxpayers are not under a civil examination or a criminal investigation by the IRS. The IRS has not contacted the Taxpayers about any of the delinquent International Information Returns that are the subject of this submission. The Foreign Entities that are the subject of
Original Return. A Form 8938 was timely filed by the Taxpayers with the Original Return and is being amended today to reflect the correct number of Forms 5471 and 8865 in Part IV required to be filed by the Taxpayers, as well as adding reporting on one additional Non-BRH Related Entity. The Taxpayers were
een subject to tax penalties. The Taxpayers are not under a civil examination or a criminal investigation by the IRS. The IRS has not contacted the Taxpayers about any of the delinquent International Information Returns that are the subject of this submission. The Foreign Entities that are the subject of
al Return. A Form 8938 was timely filed by the Taxpayers with the Original Return and is being amended today simply to reflect the correct number of Forms 5471 and 8865 in Part IV required to be filed by the Taxpayers. The Taxpayers were unaware of their obligation to file the International Information Ret
een subject to tax penalties. The Taxpayers are not under a civil examination or a criminal investigation by the IRS. The IRS has not contacted the Taxpayers about any of the delinquent International Information Returns that are the subject of this submission. The Foreign Entities that are the subject of
Original Return. A Form 8938 was timely filed by the Taxpayers with the Original Return and is being amended today to reflect the correct number of Forms 5471 and 8865 in Part IV required to be filed by the Taxpayers as well, as adding reporting on two additional Non-BRH Related Entities. The Taxpayers we
Entities connected to both Taxpayers and Forms 5471
Leon Black
PERSONAP Professional Holdings LP
ORGANIZATION
Deloitte
ORGANIZATIONDebra Black
PERSONthe Internal Revenue Service's
ORGANIZATIONthe "Partnership"
ORGANIZATIONPaul, Weiss, Rifkind
ORGANIZATIONthe Foreign Entities
ORGANIZATIONWharton & Garrison LLP
ORGANIZATIONDelinquent International Information Return Submission Procedures
ORGANIZATIONAAA GUERNSEY LIMITED
ORGANIZATIONAAA ASSOCIATES LP
ORGANIZATIONREM-Co
ORGANIZATIONAPOLLO PRINCIPAL HOLDINGS VIII LP
ORGANIZATIONAPO FC-GP
ORGANIZATIONAPOLLO ADVISORS VII
ORGANIZATIONAPOLLO SOMA II ADVISORS LP
ORGANIZATIONAPOLLO LIFE ASSET LTD
ORGANIZATIONADIC LIFE ADVISORS LP
ORGANIZATIONBRH HOLDINGS GP LTD
ORGANIZATION