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efta-efta00621096DOJ Data Set 9OtherAPOLLO
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Unknown
Source
DOJ Data Set 9
Reference
efta-efta00621096
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6
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0
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APOLLO
Tax Receivable Agreement (TRA) Payment Workbook
Tax Year 2009
Parnter Version
4/19/2010
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 Year 2009
TRA payment
$ 15,027,917
2009 Payment
TRA Holder
TRA Ownership %
Amount
Leon Black
41.0768%
6,172.991
EFTA00621098
APO Corp Related Taxable Income
Tax Benefits Schedule
Tax Year 2009
grin p ndix
Tax Receivable Agreement
(TRA) Reference (Article
APO Corp. 2039 Tax Year Realized Tax Benefit
3.01(b)(1).(3)
(Dsnent)
$
17.654.514
3.01(b)(2).(4)
Excess Realized Tax Benefit (Detriment)
3.01(b)
Adjusted Realized Tax Benefit
17.654.514
3.01(b)
85% Per TRA
85%
Tax Benefit Payment (includes Imputed Interest wider IRC
3.01(b)
Section 483)
15.006.337
IRC Section 483 Imputed Interest (Instalment sale rules)
1.871.766 (1)
2038 Section 483 Interest Rale (5.15%)
Present Value of Tax Benefit Payment from Apell 21. 2010
to July 14. 2007 - Total Sales Proceeds
13.134.571 (2)
3.01(b)
Interest Amount Per TRA (Through April 21. 2010)
21.580 (3)
total Net i ax tienele - xe.. I ax Benefit Payment related
3.01(b)
2009 Tax Return
1
15.027.917
Notes:
(1) To cakulate the amount of imputed insiallmeM sate 'Serest that is taxable on the tax return the Applicable
Federal Rate (MR) that applies to the term of the instalment sale on the dale of the sale (July 13. 2007) was
used. The MR was 5.15%.
(2) The present value of the Tax Benellt Payment Is calculated
using the following lormula:
Amount of Future Payment
1 • (N of days July 15.2007 to April 21. 2010)/365 x Annual Interest Rate)
Amount of Future Payment
Annual Interest Rate (Long term AFR fct July 2008)
2 Year (July 14.2007 through July 14. 2009)
a of Days (July 15.2009 through April 21. 2010)
15.006.337
5.15%
2 Year
280 Days
(3) Interest is calculated tram the due date of the 2009 Tax Return (anneal extensions).
Please see the attached calculation.
4016
EFTA00621099
APO Corp Related Taxable Income
Tax Benefit Schedule - Realized Tax Benefit Calculation (Pg 1)
Tax Year 2009
Realized Tax Benefit Calculation - Article III
Tax Benefit Schedule - Article II Section 2.03
Item
zuuu Non-
Stepar Tax
2009 Actual
Liability
'Difference
Partnership Distributive Share Income/(Loss)
$45,753,380
Standalone APO Corp Income
($971,035)
$45,753,380
($971,035)
743 Amortization
(65,198,441)
65,198,441
Sec 483 Imputed Interest Related to 754 election
(1,266,097)
1,266,097
Interest Expense on Late Payment
(86,561)
86,561
State & Local Taxes
(3,068,990)
(14,150)
(3,054,840)
Taxable Income
$41,713,355
($21,782,904)
63,496,259
Federal Income Tax
14,599,674
Federal Tax Liability
14,599,674
2009 State Income Tax (NY, NYC, CA)
3.068,990
14.150
Total 2009 Tax Liability
S
17,668.664
S
14,150
Realized Tax Benefit Calculation
—
I
Item
Amount
Non-Stepped Up Tax Liability
$
17,668,664
Actual Liability
14,150
Realized Tax Benefit (Detriment)
$
17,654,514
5 of 6
EFTA00621100
February, 2010
March, 2010
APO Corp Related Taxable Income
TRA Late Payment Interest Amount Calculation
Tax Year 2009
Tax Benefit Payment
Interest Amount 1
Total Payment
$
15,006.337
21.580
15,027,917
•
Date for LIBOR
February 26. 2010
March 30, 2010
LTHOH (assumed
to be 6 month
rate)
Plus 100
Basis
Points
Hate for the
Interest
Amount
Cumulative Tax
Monthly
Benefit Payment
Interest
Amount
1 Reflects TRA payment occuring on April 21, 2010.
0.387°,0
0.442%
6 of 6
I Il0c,
I ll0c,
9.123
12.456
15,015,460
15,027.917
EFTA00621101
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