Epstein Secrets

hare of a trust's assets if it were then to terminate. No Principal shall ever be a member of the Group of another Principal. "Heritage Fund" means Fund IV and/or Fund V, as applicable. 7 Otion—US4-Hen03.$9.4 Dckt: US1-10770389v1$ EFTA00808231 "Heritage Points" means the nominal number of "points"

a taxing authority, and shall include all interest, penalties and additions imposed with respect to such amounts. "Tax Receivable Agreement" means the Tax Receivable Agreement, dated as of the date the Prior Agreement, as amended through the date here by and among APO Corp., a Delaware corporation, Apollo Princi al Holdin

trust's assets if it were then to terminate. No Principal shall ever be a member of the Group of another Principal. "Heritage Funds" means each of Fund IV and Fund V. "Heritage Points" means the nominal number of "points" with respect to each Heritage Fund contributed by each Partner as set forth on S

ther similar interests or the sole general partner interest or managing member or similar interest of such Person. "Tax Receivable Agreement' means the Tax Receivable Agreement, dated as of the date hereof, by and among APO Corp., a Delaware corporation, Apollo Principal Holdings II, L.P., a Delaware limited partnership, A

hare of a trust's assets if it were then to terminate. No Principal shall ever be a member of the Group of another Principal. lieritage Fund" means Fund IV and/or Fund V, as applicable. "Heritage Points" means the nominal number of "points" with respect to each Heritage Fund contributed by each Princip

taxing authority, and shall include all interest, penalties and additions imposed with respect to such amounts. "Tax Receivable Agreement" means the Tax Receivable Agreement, dated as of the date hereof, by and among APO Corp., a Delaware corporation, Apollo Principal Holdings II, L.P., a Delaware limited partnership, A

s in AOG units should be 35%. Under the current ownership structure, BFP owns 21% of the profits interests in AOG, 33.9% of the profits interests in Fund IV and 26.2% of the profits interests in Fund V.3 Accordingly, BFP's profits interests in AOG, including the two Heritage Funds, should not exceed the

s or artwork that cannot be managed. In addition, the use of CLATs in Leon's estate planning should not have any impact on benefits available under the Tax Receivable Agreement ("TRA"). b. Self-Dealing Rules We considered application of the self-dealing rules to an exchange of Apollo Operating Group ("AOG") units for Apol

hare of a trust's assets if it were then to terminate. No Principal shall ever be a member of the Group of another Principal. "Heritage Fund" means Fund IV and/or Fund V, as applicable. "Heritage Points" means the nominal number of "points" with respect to each Heritage Fund contributed by each Princip

a taxing authority, and shall include all interest, penalties and additions imposed with respect to such amounts. "Tax Receivable Agreement" means the Tax Receivable Agreement, dated as of the date the Prior Agreement, as amended through the date hereof, by and among APO Corp., a Delaware corporation, Apollo Principal Hol