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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-
n reached ky that review-it was determined-that the Taxpayers were-eblia_an obligation to file the International Information Returns with respect to the Foreign Entities, including the Non-BRH Related Entities, for 2012, which the Taxpayers are now Eleing,satisfying via the filing of the Amended Return. The Taxpaye
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
onstached Jy that review, it-was determined-that the Taxpayers were-ebliatn obligation to file the International Information Returns with respect to the Foreign Entities for 2014-fineluding-seme-rniner-reperting-eltanges-te-the-previeusl.frfiled-BRHafRi-884-5), which the Taxpayers are now deingsatisfving via the fil
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
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 Foreign Entities, including the Non-BRH Related Entities, for 2011, which the Taxpayers are now doing via the filing of the Amended Return. The Taxpayers are neithe
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
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 Foreign Entities for 2013 (including some minor reporting changes to the previously filed BRH Form 8865), which the Taxpayers are now doing via the filing of the Am
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
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 Foreign Entities, including the Non-BRH Related Entities, for 2012, which the Taxpayers are now doing via the filing of the Amended Return. The Taxpayers are neithe
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
any obligation to file the International Information Returns with respect to BRH or the many other Foreign Entities held through BRH. In addition, the Foreign Entities are indirectly or constructively owned, in whole or in part, by BRH, and the tax information of such Foreign Entities is not directly reported to th
reported by the Taxpayers, or in the tax liability owed by the Taxpayers, for 2008, which was timely paid. The Original Return was prepared by the Taxpayers' professional accountants at Konigsberg Wolf & Co., P.C. ("Konigsberg"), and the Amended Return along with the accompanying International Informati
n 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 Foreign Entities, including the Non- BRH Related Entities, for 2008, which the Taxpayers are now doing via the filing of the Amended Return. The Taxpayers are neith
reported by the Taxpayers, or in the tax liability owed by the Taxpayers, for 2007, which was timely paid. The Original Return was prepared by the Taxpayers' professional accountants at Konigsberg Wolf & Co., P.C. ("Konigsberg"), and the Amended Return along with the accompanying International Informati
n 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 Foreign Entities, including the Non- BRH Related Entities, for 2007, which the Taxpayers are now doing via the filing of the Amended Return. The Taxpayers are neith
Entities connected to both Taxpayers and the Foreign Entities
the "Partnership"
ORGANIZATIONthe Internal Revenue Service's
ORGANIZATIONPaul, Weiss, Rifkind
ORGANIZATIONDebra Black
PERSONLeon Black
PERSON
Deloitte
ORGANIZATIONAP Professional Holdings LP
ORGANIZATIONAAA ASSOCIATES LP
ORGANIZATIONAAA GUERNSEY LIMITED
ORGANIZATIONDelinquent International Information Return Submission Procedures
ORGANIZATIONAPOLLO SOMA II ADVISORS LP
ORGANIZATIONWharton & Garrison LLP
ORGANIZATIONAPO FC-GP
ORGANIZATIONAPOLLO PRINCIPAL HOLDINGS VIII LP
ORGANIZATIONREM-Co
ORGANIZATIONAPOLLO ADVISORS VII
ORGANIZATIONForms 5471
ORGANIZATIONAPOLLO EPF CAPITAL MANAGEMENT LIMITED
ORGANIZATIONAPOLLO LIFE ASSET LTD
ORGANIZATIONAPOLLO GAUCHO GENPAR LTD
ORGANIZATION