n reached ky that review-it was determined-that the Taxpayers were-eblia_an obligation to file the International Information Returns with respect to the Foreign Entities, including the Non-BRH Related Entities, for 2012, which the Taxpayers are now Eleing,satisfying via the filing of the Amended Return. The Taxpaye

onstached Jy that review, it-was determined-that the Taxpayers were-ebliatn obligation to file the International Information Returns with respect to the Foreign Entities for 2014-fineluding-seme-rniner-reperting-eltanges-te-the-previeusl.frfiled-BRHafRi-884-5), which the Taxpayers are now deingsatisfving via the fil

LLP. As a result of that review, it was determined that the Taxpayers were obligated to file the International Information Returns with respect to the Foreign Entities, including the Non-BRH Related Entities, for 2011, which the Taxpayers are now doing via the filing of the Amended Return. The Taxpayers are neithe

LLP. As a result of that review, it was determined that the Taxpayers were obligated to file the International Information Returns with respect to the Foreign Entities for 2013 (including some minor reporting changes to the previously filed BRH Form 8865), which the Taxpayers are now doing via the filing of the Am

LLP. As a result of that review, it was determined that the Taxpayers were obligated to file the International Information Returns with respect to the Foreign Entities, including the Non-BRH Related Entities, for 2012, which the Taxpayers are now doing via the filing of the Amended Return. The Taxpayers are neithe

any obligation to file the International Information Returns with respect to BRH or the many other Foreign Entities held through BRH. In addition, the Foreign Entities are indirectly or constructively owned, in whole or in part, by BRH, and the tax information of such Foreign Entities is not directly reported to th

n LLP. As a result of that review, it was determined that the Taxpayers were obligated to file the International Information Returns with respect to the Foreign Entities, including the Non- BRH Related Entities, for 2008, which the Taxpayers are now doing via the filing of the Amended Return. The Taxpayers are neith

n LLP. As a result of that review, it was determined that the Taxpayers were obligated to file the International Information Returns with respect to the Foreign Entities, including the Non- BRH Related Entities, for 2007, which the Taxpayers are now doing via the filing of the Amended Return. The Taxpayers are neith