EFTA02518093

From: jeffrey E. <[email protected]> Sent: Thursday, May 1, 2014 1:25 PM To: Thomas Turrin Cc: Richard Joslin; Abel Goce; tax Subject: Re: GSCO IMY accounts when will i have the draft77777 On Thu, May 1, 2014 at 3:24 PM= Thomas Turrin < > wrote: Yes...agreed Sent from my Verizon Wireless 4G LTE =ROID Richard Joslin «mailto:a > wrote: Please dont forget to take out $250K of interest income (GSCO) in the =012 amended return On Mar 28, 2014, at 4:04 PM, "Richard Joslin" wrote= See screenshot belo= that shows BRH ownership of AP Professionals which owns Apollo Operating =roup. BRH Holdings LP has a 98- prefix (a foreign partnership). =AO Foreign partnerships are assigned EIN's with a 98 prefix http://www.irs.goviirm/part21/irm_21-007-013r.htmlqa>. AP Professional Holdings, L.P., an exempted limited partnership=formed under the laws of the Cayman Islands, <http://www.irs.gov/irm/part2l/irm_21-007-013r=html> http://www.sec.gov/Archiveiledgar/data/1411494/000119312513204748/d532543de=101.htm <http://www.sec.gov/Archivesiedgar/data/1411494/000119312513204744d532543dex101.htm> The foreign partnerships are non-withholding partn=rship for purposes of Sec 1441 (they have not elected with the IRS to be t=eated as a withholding foreign partnership for US tax purposes. AP Professionals ha= an account at GSCO. Since AP professionals is a non-withholding foreign p=rtnership and since the owner of AP Professioanls (BRH) is also a non-with=olding partnership, GSCO is reporting income directly to the US owners of BRH. This is accomplished by AP =rofessional issuing a W-8 IMY to GSCO and giving GSCO the W-8-IMY of BRH w=ich reflects the US owners of BRH. GSCO issues 1099's direct=y to US owner. We know that BRH is owned by BFP LP (not LDB). The BRH K-1 was picked up by BFP but this 1099 was reported =irectly on LDB's EFTA_R1_01653604 EFTA02518093 1040 (should have been BFP pro forma K1 (if not r=ported by BRH)). The AP Professional LP income was picked up by BRH =oldings. I confirmed with Apollo. Summary: GSCO=1099s issued under LEON BLACK IMY-AP PROFESSIONAL HOLDINGS LP were r=ported twice in 2012 — once on LDB 1040 and once on K-1 for BFP LP= Taxable income over=tated by - $250K. Accounts: The pages upload to=portal of the 1099 for have been left out — I can =80 t see for certain but likely also IMY-AP PROFESSIONAL HOLDINGS LP Oddly I don =99t see these GSCO accounts for AP Professional are reported on 1040 for 2=11 but they are reported in 2010 (in addition to other GSCO accounts) and =009. 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