From: "Barry J. Cohen"

From: "Barry J. Cohen" To: jeffrey E. <[email protected]> Subject: RE: FW: Plane depreciation--PRIVILEGED AND CONFIDENTIAL Date: Mon, 21 Aug 2017 15:19:49 +0000 We should have structure charts and an explanation going out shortly. Easier to understand once you see that. From: jeffrey E. [[email protected]] Sent: Monday, August 21, 2017 10:07 AM To: Barry J. Cohen < > Subject: Re: FW: Plane depreciation--PRIVILEGED AND CONFIDENTIAL 135.? Fed taxes ? On chartering - who owns ? On Mon, Aug 21, 2017 at 10:03 AM Barry J. Cohen < > wrote: We will put the plane in an entity that leases/charters it out to others. Given that the ownership entity will be 100% in the business of leasing the plane, EY and our law firm advise that 100% of depreciation will be deductible. We are confirming just how much personal use will be tolerated in this structure since if all the plane owner does is lease the plane to Leon for his personal use, the IRS might take issue with our position. But between art investing and Apollo use, even in 2017, we think we'll get comfortable. I hope to have a more elaborate proposal out to you today. From: jeffrey E. [mailto:[email protected]] Sent: Saturday, August 19, 2017 7:54 AM To: Barry J. Cohen Subject: [External] hups:/iwww.bjtonline.com/business-jet-news/how-to-avoid-losing-aircraft-depreciation-deductions the only releveant part is when the 650 comes on line. ex if it is only novemeber and debra uses it predominantly . for the holidays. the " year " use would be all personal. 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], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved This email and any files transmitted with it are confidential and intended solely for the person or entity to whom they are addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other than the intended recipient is prohibited. If you have received this email in error please contact the sender and delete the material from any computer. Apollo Global Management, LLC EFTA00654631 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 j @gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00654632