Epstein Secrets

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

urged to consult their own tax advisors regarding the tax consequences of an investment in Class A shares. Passive Foreign Investment Companies and Controlled Foreign Corporations. It is possible that we will invest in non-U.S. corporations treated as PFICs or CFCs. A PFIC is defined as any foreign corporation with respect to

C, a Delaware limited liability company (the "Manager). The Fund is managed by the Manager. The general partner of the Fund is Andra Managers LLC, a Cayman Islands limited liability company (the "General Partner). SVCs represent an indirect fractional non-voting economic interest in the sole limited pa

ns, including investments in "controlled foreign corporations" ("CFCs") and "passive foreign investment companies" ("PFICs"), both described below. Controlled Foreign Corporations. If a U.S. person owns, directly, indirectly or constructively, 10% or more of the combined voting power or value of the stock of a foreign corporat

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

g investments in "controlled %reign corporations" ("CFCs") and "passive foreign investment companies" ("PFICs"), both described immediately below. Controlled Foreign Corporations. If a U.S. Person, including any U.S. Limited Partner owns actually or constructively at least 10% of the voting stock of a non-U.S. corporation, su