EFTA Document EFTA01793409

From: Thomas Turrin Sent: Thursday, May 1, 2014 124 PM To: Richard Joslin Cc: Abel Goce; Jeffrey Epstein; tax Subject: Re: GSCO IMY accounts Yes...agreed Sent from my Verizon Wireless 4G LTE =ROID Richard Joslin wrote: Please dont forget to take out $250K of interest income (GSCO) in the =012 amended return On Mar 28, 2014, at 4:04 PM, "Richard Joslin" wrote: 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). = Foreign partnerships are assigned EIN's with a 98 prefix http://www.irs.gov/irm/part21/irm_21.007.013r.html <http://www.irs.gov/irm/part21/irm_21.007.013r=html> . AP Pro=essional Holdings, L.P., an exempted limited partnership formed under the =aws of the Cayman Islands, http://www.sec.gov/Archives/edgar/data/1411494/000119312513204748/d532543de=101.htm chttp://www.sec.gov/Archivegedgar/data/1411494/00011931251320474./d532543dex101.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 directly to =5 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 reporte= by BRH)). The AP Professional LP income was picked up by BRH Holdin=s. 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. EFTA_R1_00126370 EFTA01793409 Taxable income over=tated by "" $250K. Accounts: The pages upload to=portal of the 1099 fo have been left out — I can't see fo= certain but likely also IMY-AP PROFESSIONAL HOLDINGS LP Oddly I don't see=these GSCO accounts for AP Professional are reported on 1040 for 2011 but =hey are reported in 2010 (in addition to other GSCO accounts) and 2009. Ve=y small amounts in those years. <image001.png> &=bsp; &=bsp; CONFIDENTIALITY STATEMENT: The information contained in this elect=onic communication, including any and all attachments and enclosures, may be privileged and is strictly confidential, intended s=lely for the use of the person(s) identified above to receive this communi=ation. If you are not the person(s) identified above to receive this commu=ication, you are hereby notified that you may not disclose print, copy, disseminate, or otherwise use the i=formation contained herein. If you are an employee or agent of the person(=) identified above to receive this communication and, as such, you have be=n authorized to deliver this communication to such person(s), you may disclose, print, copy, disseminate, or otherwis= use the information contained in this communication solely for the purpos= of such delivery. Unauthorized interception and/or use of this communicat=on are/is strictly prohibited and may be punishable by law. If you have received this communication in error= please reply and notify the sender (only) of that fact and delete the com=unication, including any and all attachments and enclosures, from your com=uter or other electronic device on which you may have received this communication. CIRCULAR 230 DISCLOSURE: To insure compliance with requirements imposed by the Internal Reven=e Service, we inform you that any tax advice contained in this communication (including any and all attachments), unles= expressly stated otherwise, was not intended or written to be used and ca=not be used for the purpose of (i) avoiding tax-related penalties imposed =y the Internal Revenue Code or (ii) promoting, marketing, or recommending to another party any transactio=(s) or tax-related matter(s) addressed herein. This communication may not =e forwarded (other than to the addressee(s) identified above) without our =xpress written consent. 2 EFTA_R1_00126371 EFTA01793410