n arrangements with respect to the effect of the Basis Adjustment and Imputed Interest (in each case, as defined herein) on the actual liability for Taxes of APO Corp.; WHEREAS the parties to the Original Tax Receivable Agreement together with Apollo Principal VI, Apollo Principal VIII, and AMH Holdings now desire

, CA) 4 225 697 26,535 35,754,826 26,535 Total 2012 Current Tax Liability 35 754 826 S A. With respect to any Taxable Year, the liability for Taxes of APO Corp., including with respect, directly or Indirectly, to the income and gains allocable to APO Corp. from any Partnership in which APO Corp. owns 'an in