ll be treated as gain or loss from the sale of a capital asset. That would result in all the gain to Leon being capital gain (and a capital loss to APO Corp). Have to look more closely at this issue of whether the right relates to ordinary assets to the extent of the ordinary assets of AMH, but on the su

EFTA00621096 APOLLO Page MA Related Payment 3 Net Tax Benefit Allocated 4 Tax Benefit Schedule - Calculations for the 2009 tax Year of APO Corp 5 Interest Amount Calculation 6 Tax Benefit Schedule - Realized Tax Benefit Calculation 2 of 6 Index EFTA00621097 TRA Payment Tax Yea

projected utilization — projected taxable income) and future TRA (updated Duff & Phelps valuation of management company side of Apollo business, ie APO Corp) From: Richard D'Agostino Sent: Monday, June 09, 2014 12:18 PM To: Richard Joslin Subject: for JEE EFTA00696207

From: Richard Joslin <I To: Jeffrey E. <[email protected]> CC: Brad Wechsler <I Subject: FW: TRA Date: Thu, 28 Jan 2016 18:25:49 +0000 APO Corp pays TRA payment directly to BFP, MJR Foundation, MJH Partners (per Apollo Finance). I have call into Katie for clarification. Here is link to FIRS

t Principal's estate should be tax neutral to all parties at each level of the distribution chain. The exchange of the AMH preferred interests with APO Corp for AGM Class A Shares should permit a basis step up for the fair market value of the preferred interest in the assets of AMH that should be allocab

uidation preference of $800m, would be limited in participation to a coupon that reflects a market rate of return and would net-be exchangeable with APO Corp for eettiityClass A Shares of AGM based upon the trading price of AGM Class A Shares at the time of the exchange. The coupon rate on the preferred

LB Death/Disability Analysis — Summary of Analysis by Document I. Tax Receivable Agreement (the "TRA"), dated July 13, 2007 Parties to Agreement APO Corp.. Apollo Principal Holdings II, L.P., Apollo Principal Holdings IV. L.P. and Apollo Management Holdings, L.P. Key Definitions "Basis Adjustment"

s. Heritage adjustment is carry from Fund V and VI that is divvyed up between MR/JH and LDB. As a founder sells BRH in taxable exchange, the public APO Corp acquires a slice of Fund V and VI carry vehicle. BRH receives lesser carry in future and as a consequence LDB gets less Heritage adjustment. APO Cor