Case File
efta-efta00841519DOJ Data Set 9OtherFrom: Richard Joslin -4
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DOJ Data Set 9
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efta-efta00841519
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From: Richard Joslin -4
To: "[email protected]" [email protected]>, Brad Wechsler
Subject: FW: Questions on BRH
Date: Wed, 04 Nov 2015 13:23:50 +0000
Attachments: Leon_Black_Q3_Estimates_(00000003)_6.pdf;
Leon_Black_Q3_Estimates_(00000003)_extract.pdf
Please see attached. Apollo is paying out AOG units as stock compensation to employees. This gives rise to a
tax deduction. Cash earnings are not reduced by stock compensation. Cash earnings/ distributions will be
greater than taxable income. The excess of cash distributed over taxable income will reduce tax basis. Note that
the transfer of AOG units to employees reduces the number of AOG units that the founders/ AP Professionals
own. The September projection estimates stock compensation $0.88/sh. Suzanne Wong in the tax group sent
the message last night regarding stock compensation.
From: Suzanne Wong
Sent: Tuesday, November 3, 2015 7:25 PM
To: Richard Joslin
Subject: RE: Questions on BRH
Rich —
Left you a voicemail also. The following are items that would not reduce cash distributions but are tax deductions:
1) Noncash compensation such as the RSU's
2) Depreciation and Amortization
As noted on my voicemail, depreciation and amortization are not as impactful as the noncash compensation. Also we are
revisiting the historical data in the basis rollforward to confirm amounts.
Best,
Suzanne Wong I Apollo Global Management L.L.C.
730 Firth auc-n.
Office
From: Richard Joslin [mailto:
Sent: Monday, November 02, 2015 3:33 PM
To: Suzanne Wong
Subject: FW: Questions on BRH
From: Katie Gregory Newman [mailto
Sent: Friday, October 30, 2015 5:49 PM
To: Richard Joslin .ic
>
Subject: Questions on BRH
Rich,
EFTA00841519
Thanks for your email — sorry our schedules didn't fit today. On Monday I will be in Luxembourg — it might be easiest for
us to connect late my time, so do you have any availability in the late afternoon EST?
I understand from a few conversations with John Suydam and others that your and Jeffrey's focus is on ensuring that
Leon's "negative basis" is limited to his deferred Tufts gain from the 2007 leveraged distribution which is a known
amount. Jeffrey indicated that there was some concern that this amount could have increased as a result of cash
distributions in excess of tax allocations (accompanied by additional allocations of AMH liabilities). I asked our tax
compliance group to compile the cash and tax data over the past 5 years and received the following. You will see that the
fact that cash was greater than taxable income in 2013 and 2014 was largely due to the unwinding of the "Harvest"
transaction which occurred in 2012.
To the extent that taxable income continues to match cash in the aggregate over the years, I believe we can affirm that
Leon's "negative basis" is limited to his deferred Tufts gain from the 2007 leverage distribution. Does this make sense to
you?
Happy to discuss more next week at your convenience.
Katie
From: Justin Teng
Sent: Friday, October 30, 2015 2:29 PM
To: Katie Gregory Newman
Cc: Brian Knudson; Suzanne Wong
Subject: RE: Questions from Leon's Office Directly re: Gain on Exchanges
Please see revised table as well as all supporting K-1's attached.
Tax Year
Cash Distributions -
[D]
PFIC - [A]
CY Increase/Decrease -
[B]
Taxable Income - [A] +
[B] = [C]
(Excess) / Surplus -
[C] + [D]
2010
(19,472,705)
114,552
51,978,591
52,093,143
32,620,438
2011
(88,504,186)
1,138,275
90,576,469
91,714,744
3,210,558
2012
(138,766,429)
9,062,315
304,130,864
313,193,179
174,426,750
2013
(382,641,922)
97,310,143
246,906,456
344,216,599
(38,425,323)
2014
(339,134,923)
43,979,858
260,255,321
304,635,179
(34,499,744)
Total
(968,520,165)
151,605,143
953,847,701
1,105,852,844
137,332,679
Please let me know if you need anything else.
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
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
EFTA00841520
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