This document is a draft of a Tax Receivable Agreement Letter circulated in November 2008 to the holders. It outlines the tax implications and agreements related to a transaction involving Apollo Global Management, LLC and its subsidiaries. The transaction, dated July 13, 2007, involved a contribution to APO Corp. and MO Asset Co., resulting in a tax basis adjustment under IRC Section 743(b). The letter details the tax benefits, including additional deductions and payments to holders, and the potential IRS challenges. Appendices provide calculations for the tax basis adjustment and tax benefits for the 2007 tax year.
documents/EFTA01127467.pdf
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