Epstein Secrets

JUNE 19, 2013 Overall Effect The overall effect of this plan should be the elimination of any Tufts gain [(including upon an interim exchange of AOG Units for AGM Class A Shares, except for any non-recourse debt remaining as a result of the intragroup-held AMH debt not repaid under this plan and alloca

t Principal's estate should be tax neutral to all parties at each level of the distribution chain. The exchange of the AMH preferred interests with APO Corp for AGM Class A Shares should permit a basis step up for the fair market value of the preferred interest in the assets of AMH that should be allocab

e existing TRA. Overall Effect The overall effect of this plan should be the elimination of any Tufts gain [(including upon an interim exchange of AOG Units for AGM Class A Shares, except for any non-recourse debt remaining as a result of the intergrettp-lieldintragroup-held AMH debt not repaid under thi

uidation preference of $800m, would be limited in participation to a coupon that reflects a market rate of return and would net-be exchangeable with APO Corp for eettiityClass A Shares of AGM based upon the trading price of AGM Class A Shares at the time of the exchange. The coupon rate on the preferred

ontinuing Principals." Exchanges to Pay Taxes After his death or Disability, in the event an Apollo professional other than a Principal forfeits AOG Units or other economic interests, and they are distributed to Principals and ' The document summaries contained herein are intended to address the most s

LB Death/Disability Analysis — Summary of Analysis by Document I. Tax Receivable Agreement (the "TRA"), dated July 13, 2007 Parties to Agreement APO Corp.. Apollo Principal Holdings II, L.P., Apollo Principal Holdings IV. L.P. and Apollo Management Holdings, L.P. Key Definitions "Basis Adjustment"