<table><tr><th>From:</th><th>jeffrey E. &lt;jeevacation@gmail.com&gt;</th></tr><tr><td>Sent:
To:</td><td>Thursday, May 1, 2014 1:25 PM
Thomas Turrin</td></tr><tr><td>Cc:</td><td>Richard Joslin; Abel Goce; tax</td></tr><tr><td>Subject:</td><td>Re: GSCO IMY accounts</td></tr></table>

when will i have the draft?????

- Document type: email thread screenshot (many email addresses redacted).
- Dates/times:
  - May 1, 2014 at 3:24 PM — Thomas Turrin wrote: "Yes...agreed"
  - Mar 28, 2014 at 4:04 PM — earlier message from Richard Joslin
- Key senders: Thomas Turrin; Richard Joslin (email addresses redacted).
- Key message: "Please dont forget to take out $250K of interest income (GSCO) in the 2012 amended return."
- Misc: "Sent from my Verizon Wireless 4G LTE" (mobile signature).
- Surrounding context (provided text): BRH ownership of AP Professionals, which owns Apollo Operating Group; BRH Holdings LP has a 98- EIN prefix (foreign partnership). AP Professional Holdings, L.P. is an exempted limited partnership formed in the Cayman Islands. Foreign partnerships referenced are non-withholding partnerships for Sec. 1441. References to IRS/SEC filings included (links redacted in screenshot).

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

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. Very small amounts in those years.

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