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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
of filing Forms 5471, 8865, 8858 and 8938 (the "International Information Returns") for 2011, under the Internal Revenue Service's (the "IRS") 2014 Delinquent International Information Return Submission Procedures. The Taxpayers have not been contacted by the IRS regarding the Amended Return or the International Information Returns and have a long history of
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
of filing Forms 5471, 8865, 8858 and 8938 (the "International Information Returns") for 2013, under the Internal Revenue Service's (the "IRS") 2014 Delinquent International Information Return Submission Procedures. The Taxpayers have not been contacted by the IRS regarding the Amended Return or the International Information Returns and have a long history of
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
of filing Forms 5471, 8865, 8858 and 8938 (the "International Information Returns") for 2012, under the Internal Revenue Service's (the "IRS") 2014 Delinquent International Information Return Submission Procedures. The Taxpayers have not been contacted by the IRS regarding the Amended Return or the International Information Returns and have a long history of
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
rpose of filing Forms 5471, 8865 and 8858 (the "International Information Returns") for 2010, under the Internal Revenue Service's (the "IRS") 2014 Delinquent International Information Return Submission Procedures. The Taxpayers have not been contacted by the IRS regarding the Amended Return or the International Information Returns and have a long history of
Entities connected to both REM-Co and Delinquent International Information Return Submission Procedures
Paul, Weiss, Rifkind
ORGANIZATIONAP Professional Holdings LP
ORGANIZATIONthe Foreign Entities
ORGANIZATIONLeon Black
PERSONDebra Black
PERSON
Deloitte
ORGANIZATIONthe Internal Revenue Service's
ORGANIZATIONTaxpayers
ORGANIZATIONthe "Partnership"
ORGANIZATIONAAA ASSOCIATES LP
ORGANIZATIONAAA GUERNSEY LIMITED
ORGANIZATIONAPOLLO PRINCIPAL HOLDINGS VIII LP
ORGANIZATIONAPOLLO ADVISORS VII
ORGANIZATIONAPOLLO SOMA II ADVISORS LP
ORGANIZATIONAPO FC-GP
ORGANIZATIONAPOLLO EPF CAPITAL MANAGEMENT LIMITED
ORGANIZATIONRaich Ende Malter & Co. LLP
ORGANIZATIONADIC LIFE ADVISORS LP
ORGANIZATIONAPOLLO ADMINISTRATION GP LTD
ORGANIZATIONAPOLLO LIFE ASSET LTD
ORGANIZATION