Epstein Secrets

l"); WHEREAS, each of the Partnerships is treated as a partnership for U.S. Federal income tax purposes; WHEREAS, the limited partner interests in the Apollo Operating Group (as defined herein), are exchangeable, for Federal income tax purposes, with APO Corp., APO FC and the Issuer for Class A Shares (as defined herei

., yman Islands exempted limited partnership ("Apollo Principal VIII"), Apollo Management Holdings, L.P., a Delaware limited partnership ("AMH"), AMH Holdings (Cayman), L.P., a Cayman Islands exempted limited partnership ("AMH Holdings") (together with all other Persons (as defined herein) in which APO C

partnerships, accounts, including strategic investment accounts or "SIAs," alternative asset companies and other entities for which subsidiaries of the Apollo Operating Group provide investment management or advisory services; • "Apollo Operating Group" refers to (i) the limited partnerships through which our Managing P

our European investment management business; Apollo Principal Holdings XII, M. generally holds general partner interests of certain credit funds and AMH Holdings (Cayman), M. and Apollo Management Holdings, generally hold the interests of the management companies for each of our private equity funds (includ

n 13(d) of the Exchange Act), (iv) any former or current investment professional of or other employee of an "Apollo employer" (as defined below) or the Apollo Operating Group (or such other entity controlled by a member of the Apollo Operating Group), (v) any former or current executive officer of an Apollo employer or th

. Tax Elections. We have not made and currently do not intend to make the election permitted by Section 754 of the Code with respect to us. Each of AMH Holdings (Cayman). M.. Apollo Management Holdings, M. and the entities controlled by Apollo Management Holdings, M. has made such an election while. Apollo P