Epstein Secrets

iodical income received from sources within the United States if such income is not treated as effectively connected with a trade or business within the United States. The 30% rate may be reduced or eliminated under the provisions of an applicable income tax treaty between the United States and the country in whic

nder should qualify as a -publicly offered security" within the meaning of the Plan Asset Regulations. Governmental plans, certain church plans and non-United States plans (each, a "Non-ERISA Plan"), while not subject to the fiduciary responsibility or prohibited transaction provisions of Title I of ERISA or Sec

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

Attention: Chief Legal Officer with a copy to: NYI:1694391.10 14 EFTA00621115 Paul, Weiss, Riflcind Wharton & Canton LLP 1285 Avenue of the Americas Eltailekeny-and-Myers-LL-P Tintes,Square-Tewer ;--T-imes-8qtrare New York, New York 10036NY 10019-6064 (T)-(414)--326-2000 (F) (212) 326 2061

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

as political. social and economic uncertainty affecting a country or region. Many financial markets are not as developed or as efficient as those in the United States. and as a result, liquidity may be reduced and price volatility may be higher. The legal and regulatory environment may also be different. particular

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)