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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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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 AP Professional Holdings LP and the Foreign Entities
Leon Black
PERSONthe Internal Revenue Service's
ORGANIZATIONPaul, Weiss, Rifkind
ORGANIZATIONTaxpayers
ORGANIZATION
Deloitte
ORGANIZATIONthe "Partnership"
ORGANIZATIONDebra Black
PERSONAAA ASSOCIATES LP
ORGANIZATIONAAA GUERNSEY LIMITED
ORGANIZATIONDelinquent International Information Return Submission Procedures
ORGANIZATIONWharton & Garrison LLP
ORGANIZATIONForms 5471
ORGANIZATIONAPOLLO SOMA II ADVISORS LP
ORGANIZATIONREM-Co
ORGANIZATIONAPOLLO ADVISORS VII
ORGANIZATIONAPOLLO PRINCIPAL HOLDINGS VIII LP
ORGANIZATIONAPO FC-GP
ORGANIZATIONAPOLLO GAUCHO GENPAR LTD
ORGANIZATIONAPOLLO LIFE ASSET LTD
ORGANIZATIONAPOLLO EPF CAPITAL MANAGEMENT LIMITED
ORGANIZATION