The document discusses a proposal to interpose an intercompany note between AGM and APO Corp, effected by way of a dividend. The note aims to result in future ongoing interest deductions, reducing AGM's ETR and cash taxes, increasing DNI, and boosting the trading price of AGM's Class A Shares. It includes considerations on legal, tax, and reputational issues, sizing and pricing of the note, and tax implications for US and Non-US shareholders. The document also provides economic impact projections on cash taxes and ENI tax provision, and includes a transfer pricing study for interest rate analysis.
documents/EFTA01192635.pdf
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