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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
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
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
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
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
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
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
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
r 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 properly complete the EFTA0058448
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
Entities connected to both REM-Co and the Foreign Entities
Paul, Weiss, Rifkind
ORGANIZATIONLeon Black
PERSONAP Professional Holdings LP
ORGANIZATION
Deloitte
ORGANIZATIONDebra Black
PERSONthe Internal Revenue Service's
ORGANIZATIONTaxpayers
ORGANIZATIONthe "Partnership"
ORGANIZATIONAAA GUERNSEY LIMITED
ORGANIZATIONAAA ASSOCIATES LP
ORGANIZATIONDelinquent International Information Return Submission Procedures
ORGANIZATIONAPOLLO ADVISORS VII
ORGANIZATIONWharton & Garrison LLP
ORGANIZATIONForms 5471
ORGANIZATIONAPOLLO SOMA II ADVISORS LP
ORGANIZATIONAPO FC-GP
ORGANIZATIONAPOLLO PRINCIPAL HOLDINGS VIII LP
ORGANIZATIONAPOLLO EPF CAPITAL MANAGEMENT LIMITED
ORGANIZATIONRaich Ende Malter & Co. LLP
ORGANIZATIONADIC LIFE ADVISORS LP
ORGANIZATION