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From: "Fenn, Patrick" <a To: Jeffrey Epstein <[email protected]> Subject: Re: AMH refinancing - discussion materials Date: Tue, 19 Nov 2013 13:54:56 +0000 3 works. Thanks From: Jeffrey E
scussion materials Tomorw Sony for all the typos .Sent from my iPhone On Nov 18 2013, at 6:24 PM, "Fenn, Patrick" mailto mailto:a>>> wrote: Hi Jeffrey. Do you have a minute to discuss the basic refi proposal (without the personal guarantee question) later this afternoon? Thanks From: Fenn, Patrick
From: "Fenn, Patrick" <a To: Jeffrey Epstein <[email protected]> Subject: Re: AMH refinan
uaranteeing the debt, essentially deferral of tax on what we referred to as the "Tufts gain" -- the gain that a Founder recognizes on an exchange of AOG Units for AGM Class A Shares as a result of his current negative capital account in AMH, offset by the impact of the deferral of such gain on the timing a
AGSH&F DISCUSSION DRAFT JUNE 19, 2013 Jeffrey, Here is a proposal for dealing with the negative capital accounts that the Principals have in their limited partnership interests in AMH (through
JUNE 19, 2013 Overall Effect The overall effect of this plan should be the elimination of any Tufts gain [(including upon an interim exchange of AOG Units for AGM Class A Shares, except for any non-recourse debt remaining as a result of the intragroup-held AMH debt not repaid under this plan and alloca
AGSH&F DISCUSSION DRAFT MAY 31, 2013 Jeffrey, Here is a strawman candidate for potentially dealing with the negative basis that the 3 principals have in their limited partnership interest in A
t to his will. Overall Effect The overall effect of this plan should be the elimination of any Tufts gain [(including upon an interim exchange of AOG Units for AGM Class A Shares, except for any non-recourse debt remaining as a result of the intragroup-held AMH debt not repaid under this plan and alloca
AGSH&F DISCUSSION DRAFT JUNE 19. 2013 Jeffrey, Here is a strawman-eandidateproposal for potentially-dealing with the negative basiscaoital Accounts that the 3--prineipalsPrincipals have in thei
e existing TRA. Overall Effect The overall effect of this plan should be the elimination of any Tufts gain [(including upon an interim exchange of AOG Units for AGM Class A Shares, except for any non-recourse debt remaining as a result of the intergrettp-lieldintragroup-held AMH debt not repaid under thi
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Leon Black
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Michael Cohen
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Barry Diller
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Oliver Stone
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Eric Holder
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Houston
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Apollo Global Management
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