From: Richard Joslin <
Sent: Thursday, May 1, 2014 12:20 PM
To: Thomas Turrin; Abel Goce
Cc: Jeffrey Epstein; tax
Subject: Re: GSCO IMY accounts
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:
q=pan>
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/part2l/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
<http://www.sec.gov/Archives/edgar/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.
</=pan>
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 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 rep=rted by BRH)). The AP Professional LP income was picked up by BRH Ho=dings. I
confirmed with Apollo.
</=pan>
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.
</=pan>
Accounts:
EFTA_R1_00126309
EFTA01793382
The pages upload to=portal of the 1099 for have been left out — I can'= see for certain but likely
also IMY•AP PROFESSIONAL HOLDINGS LP
cApan>
Oddly I don't=see these GSCO accounts for AP Professional are reported on 1040 for 2011 =ut they are reported
in 2010 (in addition to other GSCO accounts) and 2009= Very small amounts in those years.
<image001.png>
2
EFTA_R1_00126310
EFTA01793383