Epstein Secrets

mputed under Section 1272, 1274 or 483 or other provision of the Code and any similar provision of state, local and foreign tax law with respect to APO Corp.'s payment obligations under this Agreement. "Initial Sale" is defined in the Recitals of this Agreement. "Issuer" means Apollo Global Management, LLC

lable source of such market rate) for London interbank offered rates for U.S. dollar deposits for such month (or portion thereof). "Manage?' means AGM Management, LLC, a Delaware limited liability company and the manager of the Issuer. "Market Value" shall mean the closing price of the Class A Shares on the

on, the tax receivable agreement provides that, upon a merger. asset sale or other form of business combination or certain other changes of control. APO Corp.'s (or its successor's) obligations with respect to exchanged or acquired units (whether exchanged or acquired before or after such change of control)

rns that have been geometrically linked based on capital contributions. distributions and dividend reinvestments. as applicable; 'our manager" means AGM Management. LW. a Delaware limited liability company that is controlled by our managing partners: 'permanent capital" means capital of funds that do not have r

tain circumstances. payments could be made to our managing partners and contributing partners under the tax receivable agreement in excess of 85% of APO Corp.'s actual cash tax savings. In general. estimating the amount of payments that may be made to our managing partners and contributing partners under the

Registrant's Registration Statement on Form S-I (File No. 333-150141)). 10.1 Amended and Restated Limited Liability Company Operating Agreement of AGM Management. LLC dated as of July 10, 2097 (incorporated by reference to Exhibit 10.1 to the Registrant's Registration Statement on Form S-I (File No. 333-15014

m the portion of our business that we hold through APO Corp. will be subject to U.S. Federal corporate income tax and other taxes. As the holder of APO Corp.'s shares, we will not be taxed directly on earnings of entities we hold through APO Corp. Distributions of cash or other property that APO Corp. pays

ur Shares % Series A Preferred Shares % Series A Preferred Shares (the "Series A Preferred Shares" or the "shares"). When, as, and if declared by AGM Management, LLC, our manager, distributions on the Series A Preferred Shares will be payable quarterly on March 15, June 15, September 15 and December 15 of ea