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at Raich Ende Matter & Co. LLP ("REM-Co"). Background The Taxpayers own interests in a wide variety of entities related-teaffiliated with Apollo Global Management, LLC ("Apollo"), the publicly traded alternative asset manager, through their interest in BRH Holdings, L.P. ( I ("BRH" or the "Partnership"). Sine
d Deloitte (Apollo's tax 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 t
s at Raich Ende Malter & Co. LLP ("REM-Co"). Background The Taxpayers own interests in a wide variety of entities relatecHeaffiliated with Apollo Global Management, LLC ("Apollo"), the publicly traded alternative asset manager, through their interest in BRH Holdings, L.P. (EIN: ("BRH" or the "Partnership"). Si
d Deloitte (Apollo's tax 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
ating Group (or such other entity controlled by a member of the Apollo Operating Group). With respect to any person, "Apollo employer" means Apollo Global Management, LLC or such other entity controlled by Apollo Global Management, LLC or its successor as may be such person's employer but does not include any por
NSIDERATIONS The following discussion of the material U.S. Federal tax considerations relating to an investment in Class A shares is the opinion of Paul, Weiss, Rifkind. Wharton & Garrison LLP, our U.S. Federal income tax counsel. For purposes of this section, references to "Apollo." "we." "our." and "us" mean only
Entities connected to both Global Management and Paul, Weiss, Rifkind
Leon Black
PERSON
Lesley Groff
PERSONWharton & Garrison LLP
ORGANIZATIONthe Foreign Entities
ORGANIZATION
Deloitte
ORGANIZATIONDebra Black
PERSONthe Internal Revenue Service's
ORGANIZATIONTaxpayers
ORGANIZATIONthe "Partnership"
ORGANIZATIONAP Professional Holdings LP
ORGANIZATIONForms 5471
ORGANIZATION
Bloomberg L.P.
ORGANIZATIONWeiss
PERSON
Eric Holder
PERSONDelinquent International Information Returns
ORGANIZATIONthe District of Columbia
LOCATIONThe Original Return
ORGANIZATION