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e rules and regulations promulgated thereunder (the "3(c)(1) Fund") and SAB Overseas Fund, Ltd., an exempted company organized under the laws of the Cayman islands for non-U.S. investors and for certain tax-exempt U.S. investors (the "Offshore Fund"), each of which has an investment program substantial
d to consult with their own tax advisers with respect to the application of the investment interest limitation in their particular tax situations. Deductibility of Partnership Investment Expenditures by Noncorporate Limited Partners. Investment expenses (esz, investment advisory fees) of an individual, trust or estate are deductible only to the
ns. 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 Principal
excluded from net investment income, unless a holder of Class A shares elects to pay tax on such gain or dividend income at ordinary income rates. Deductibility of Partnership Investment Expenditures by Individual Partners and by Trusts and Estates. Subject to certain exceptions, all miscellaneous itemized deductions of an individual taxpayer, an
rofession, business or employment, the person will be required to report such knowledge or suspicion to (i) the Financial Reporting Authority of the Cayman Islands, pursuant to the Proceeds of Crime Law (2014 Revision) of the Cayman Islands if the disclosure relates to criminal conduct or money launder
es and income from different types of activities, certain investors may not be able to use losses from the Partnership to reduce income therefrom. Deductibility of Partnership Investment Expenditures by Individual Partners and by Trusts and Estates. Subject to certain exceptions, all miscellaneous itemized deductions of an individual taxpayer, a
Entities connected to both Cayman and Deductibility of Partnership Investment Expenditures

United States
LOCATION
the Cayman Islands
LOCATION
U.S. Treasury
ORGANIZATIONKeogh
ORGANIZATION
John F. Kennedy
PERSONDeloitte & Touche
ORGANIZATION
Tokyo
LOCATION
Dalton School
ORGANIZATION
Goldman Sachs
ORGANIZATIONFund IV
ORGANIZATIONAlbany
LOCATIONControlled Foreign Corporations
ORGANIZATIONIndividual Partners
ORGANIZATIONthe College of Arts and Sciences
ORGANIZATION