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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
al income tax purposes (should be distinguishable from thepreferred equity that was reviewed and held to be debt for federal income tax purposes in Castle Harbor 3 104773603 14.1,0 EFTA_R1_00451004 EFTA01969638 AGSH&F DISCUSSION DRAFT JUNE 19.2013 Calculation of thc value of thc preferred interests hel
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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
l income tax purposes (should be distinguishable from the preferred equity that was reviewed and held to be debt for federal income tax purposes in Castle Harbor . 3 104773603 v10 EFTA00582849
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t to his will. 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
fectively subject to estate tax. 7. Impact on the tax effects if the preferred interests were treated as debt for federal income tax purposes (ala Castle Harbor decision). 8. Would the tax effects on basis/step up at death/estate tax considerations/non-tax considerations be the same if the SPV/principals ac
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Entities connected to both AOG Units and Castle Harbor
