EFTA02365292

From: Okun, Brad R Sent: Tuesday, December 27, 2016 2:25 PM To: Jeffrey E. Subject: RE: I don't think we can argue that the 8865s filed by Apollo provided all the p&I for the pships, since as a category 2 filer they were only required to provide info as to their share. If all shares were pro rata, the IRS could extrapolate, but I don't believe anything in the information returns makes that clear. I am confirming with Apollo. Brad R. Okun I Partner Paul, Weiss, Rifkind, Wharton & Garrison LLP 1285 Avenue of the Americas I New York, NY 10019-6064 (212) www From: Jeffrey E. [mailto:[email protected]] Sent: Tuesday, December 27, 2016 9:22 AM To: Okun, Brad R Subject: further thoughts/? please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved This message is intended only for the use of the Addressee and may contain information that is privileged and confidential. If you are not the intended recipient, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this communication in error, please erase all copies of the message and its attachments and notify us immediately. EFTA_R1_01360467 EFTA02365292