the Foreign Entities
ORGANIZATIONDelinquent International Information Return Submission Procedures
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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
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
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
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
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
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
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
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
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
rpose of filing Forms 5471, 8865 and 8858 (the "International Information Returns") for 2008, 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
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
rpose of filing Forms 5471, 8865 and 8858 (the "International Information Returns") for 2007, 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 the Foreign Entities and Delinquent International Information Return Submission Procedures

Deloitte
ORGANIZATIONDebra Black
PERSONLeon Black
PERSONthe Internal Revenue Service's
ORGANIZATIONTaxpayers
ORGANIZATIONthe "Partnership"
ORGANIZATIONAP Professional Holdings LP
ORGANIZATIONPaul, Weiss, Rifkind
ORGANIZATIONAAA GUERNSEY LIMITED
ORGANIZATIONAAA ASSOCIATES LP
ORGANIZATIONAPO FC-GP
ORGANIZATIONAPOLLO PRINCIPAL HOLDINGS VIII LP
ORGANIZATIONAPOLLO SOMA II ADVISORS LP
ORGANIZATIONAPOLLO ADVISORS VII
ORGANIZATIONREM-Co
ORGANIZATIONAPOLLO LIFE ASSET LTD
ORGANIZATIONWharton & Garrison LLP
ORGANIZATIONForms 5471
ORGANIZATIONRaich Ende Malter & Co. LLP
ORGANIZATIONADIC LIFE ADVISORS LP
ORGANIZATION