Epstein Files Search

EFTA01086276Set 9

2015-11-03108p35,449w

capital account value of the AOG units was $1,761,816,154.° This TRA allows BFP to share in the future tax savings provided to Apollo upon the exchange ... held, the Partnership also received an annual payment from Apollo in connection with the TRA associated with the Apollo ownership sold in the July 2007 transaction which resulted from ... total assets had an aggregate market value of $2.1 billion (which excluded the TRA benefit). Since BFP had no liabilities, its aggregate partners' capital was $2.1 billion (based

https://www.justice.gov/epstein/files/DataSet%209/EFTA01086276.pdf

EFTA01101357Set 9

2014-11-11100p33,298w

also received an annual payment from Apollo in connection with the tax receivable agreement ("TRA") associated with Apollo ownership sold in the July 2007 transaction which resulted from the reorganization ... total assets had an aggregate market value of $3.1 billion (which excluded the TRA benefit). Since BFP had only a $4.2 million payable its aggregate partners' capital was $3.1 billion ... Transfer and exchange restrictions remove the ability to participate in a liquid market. The TRA outlines how the tax benefit derived from an AOG Unit exchange is shared between

https://www.justice.gov/epstein/files/DataSet%209/EFTA01101357.pdf

EFTA01101757Set 9

2015-01-21100p34,068w

capital account value of the AOG units was $2,161,470,239." This TRA allows BFP to share in the future tax savings provided to Apollo upon the exchange ... held, the Partnership also received an annual payment from Apollo in connection with the TRA associated with the Apollo ownership sold in the July i2 According to the Partnership ... total assets had an aggregate market value of $2.5 billion (which excluded the TRA benefit). Since BFP had no liabilities, its aggregate partners' capital was $2.5 billion (based

https://www.justice.gov/epstein/files/DataSet%209/EFTA01101757.pdf

EFTA00605877Set 9

24p11,128w

additional basis step-up will be delivered to APO Corp., resulting in additional future TRA benefits payable to founders. ► The following examples were prepared using certain assumptions, including: ► No changes ... Effective Tax Rate (Equity + Tufts Gain) 41.1% 41.1% 41.1% 41.1% NPV of After-Tax TRA Payments (i 7.5% Discount Rate) NPV of After-Tax TRA Payments - Cash Equity Sales ... After-Tax TRA Payments - Tufts Gain $4.9 $3.1 $3.1 $11.1 NPV Total After-Tax TRA Payments $23.2 $14.8 $14.8 $52.8 NPV Value (After-Tax Proceeds + TRA Value

https://www.justice.gov/epstein/files/DataSet%209/EFTA00605877.pdf

EFTA00812184Set 9

102p54,227w

fresh estate plan. to consider modifications Alex Victoria equal does not mean same. 10. tra review , sale. , 11 brh, doc review, 12. sale of stock or art ? tax, rent sale ... fresh estate plan. to consider modifications Alex Victoria equal does not mean same. 10. tra review , sale. , 11 brh, doc review, 12. sale of stock or art ? tax, rent sale ... estate plan. to consider modifications Alex Victoria equal does not mean same. EFTA00812191 10. tra review , sale. , 11 brh, doc review, 12. sale of stock or art ? tax, rent sale

https://www.justice.gov/epstein/files/DataSet%209/EFTA00812184.pdf

EFTA02469237Set 11

2016-02-248p1,948w

denominator would =e 365. But we would need to investigate further. Under current TRA, Tufts gain gives r=se to TRA rights only if the gain is triggered in connection ... gain would be triggered by the contribution to the DAF. Accordingly, under the current TRA, the resul=ing gain caused by the contribution would not give rise to any TRA ... what amount if done next week for ex. - 2 how does =ufts gain impact TRA. not clear to me. re tufts gain, if the " loan " from agm was transferred

https://www.justice.gov/epstein/files/DataSet%2011/EFTA02469237.pdf

EFTA02366872Set 11

2016-02-246p2,066w

denominator would be 365. But we would need to investigate further. Under current TRA, Tufts gain gives rise to TRA rights only if the gain is triggered in connection with ... gain would be triggered by the contribution to the DAF. Accordingly, under the current TRA, the resulting gain caused by the contribution would not give rise to any TRA payment ... what amount if done next week for ex. - 2 how does tufts gain impact TRA. not clear to me. re tufts gain, if the " loan " from agm was transferred

https://www.justice.gov/epstein/files/DataSet%2011/EFTA02366872.pdf

EFTA01088290Set 9

2015-12-033p538w

Effective Tax Rate (Per Management) 40.35% Discount Rate 12.00% Present Value of TRA Year TRA Amortization TRA Tax Shield Days PV Factor Tax Benefit ... Aggregate Present Value of TRA Tax Benefit, rounded $187,820,000 TRA Tax Benefit Sharing Percentage 85% Net Unrestricted TRA Tax Benefit Available to Block $159,647,000 Less: Restriction ... Discount (from Exhibit G-4) 14% ($22,350,580) Net Fair Market Value of TRA Tax Benefit Available to Block, rounded $137,000,000 EFTA01088290 Confidential DRAFT COPY - for Discussion

https://www.justice.gov/epstein/files/DataSet%209/EFTA01088290.pdf

EFTA01086758Set 9

6p1,395w

Trust BRH distributions due LDB 24,034,033 35,514,885 59,548,918 TRA excl Prorate ... Distributions to 2006 Trust/LDB (3) 4 18 14 97 83 216 TRA Gross TRA Payment (4) 25 15 40 17 - 97 TRA Payment, excl Pro-rata ... TRA Payment, excl Pro-rata to LOB (In " 1 3 5 12 2 22 Recalculation 2008 2009 2010 2011 YTD Sept '12 Total Distributions AMH Mgmt Co. DNI Proxy Estimate

https://www.justice.gov/epstein/files/DataSet%209/EFTA01086758.pdf

EFTA01076062Set 9

2011-02-266p710w

APOLLO Tax Receivable Agreement (TRA) Payment Workbook Tax Year 2010 Partner Version 4'1'2011 EFTA01076062 APOLLO Page TRA Related Payment 3 Net Tax Benefit Allocated 4 Tax Benefit Schedule ... Payment to TRA Holders 5 Tax Benefit Schedule - Realized Tax Benefit - APO Corp 6 Interest Amount Calculation 2 of 6 Index EFTA01076063 TRA Payment For the Year Ended 12.31.2010 TRA ... payment $ 51,913,251 2010 Payment TRA Holder TRA Ownership % Amount Leon Black 41.0768% 21,324316 Less: 25% Deferral (5,331.079) Net Payment 15,993,237 EFTA01076064 APO Corp Related

https://www.justice.gov/epstein/files/DataSet%209/EFTA01076062.pdf

EFTA00624765Set 9

2012-12-316p727w

APOLLO Tax Receivable Agreement (TRA) Payment Workbook Tax Year 2012 Partner Version 4'8'2013 EFTA00624765 APOLLO Page TRA Related Payment 3 Net Tax Benefit Allocated 4 Tax Benefit Schedule ... Payment to TRA Holders 5 Tax Benefit Schedule - Realized Tax Benefit - APO Corp 6 Interest Amount Calculation 2 of 6 Index EFTA00624766 TRA Payment For the Year Ended 12.31.2012 TRA ... distribution $ 30,402,688 L 55,214,569 2012 • ayment AP Professionals ross-up TRA Holder TRA Ownership % Amount Ownership Distribution Total Leon Black

https://www.justice.gov/epstein/files/DataSet%209/EFTA00624765.pdf

EFTA00621096Set 9

2010-04-196p568w

APOLLO Tax Receivable Agreement (TRA) Payment Workbook Tax Year 2009 Parnter Version 4/19/2010 EFTA00621096 APOLLO Page MA Related Payment 3 Net Tax Benefit Allocated 4 Tax Benefit Schedule - Calculations ... Calculation 6 Tax Benefit Schedule - Realized Tax Benefit Calculation 2 of 6 Index EFTA00621097 TRA Payment Tax Year 2009 TRA payment $ 15,027,917 2009 Payment TRA Holder TRA Ownership ... Taxable Income Tax Benefits Schedule Tax Year 2009 grin p ndix Tax Receivable Agreement (TRA) Reference (Article APO Corp. 2039 Tax Year Realized Tax Benefit 3.01(b)(1).(3) (Dsnent

https://www.justice.gov/epstein/files/DataSet%209/EFTA00621096.pdf

EFTA01144374Set 9

2013-04-062p720w

that the prior summaries of outcomes was based on the fact that the section TRA benefit attributable to the Tufts gain in the deferral scenarios would be zero under ... current TRA. The attached deck has been modified to reflect the payment of 55% of the TRA benefits on the Tufts gain in each relevant scenario (as well as changing ... Marc) were the first partner out, based on a new assumption that the TRA can be amended to include the section 734(b) basis step up. As we expected, this

https://www.justice.gov/epstein/files/DataSet%209/EFTA01144374.pdf

EFTA00994394Set 9

2014-07-292p827w

From: Richard Kahn To: Jeffrey Epstein <jeevacation@gmail.com> Subject: Fwd: TRA Date: Tue, 29 Jul 2014 20:56:57 +0000 Sent from my iPhone Begin forwarded message: From: lawrence delson < Date ... July 28, 2014 at 3:30:22 PM EDT To:' < Subject: TRA Reply-To: lawrence delson Rich From Rich Joslin Founders own partnerships that generate management fees (MFP) and partnerships ... calculated with and without the Section 197 amortization. Apollo make a payment under the TRA on or around April 15 following year end. Given that the TRA payment arises from

https://www.justice.gov/epstein/files/DataSet%209/EFTA00994394.pdf

EFTA01036363Set 9

2018-01-232p822w

From: Richard Kahn To: Jeffrey <jeevacation@gmail.com> Subject: Fwd: TRA Date: Tue, 23 Jan 2018 20:43:05 +0000 Richard Kahn FIBRK Associates Inc. Begin forwarded message: From: lawrence delson < Subject ... TRA Date: Jul 28, 2014 at 3:30:22 PM EDT To: " "< Reply-To: lawrence delson < Rich From Rich Joslin Founders own partnerships that generate management fees (MFP) and partnerships ... calculated with and without the Section 197 amortization. Apollo make a payment under the TRA on or around April 15 following year end. Given that the TRA payment arises from

https://www.justice.gov/epstein/files/DataSet%209/EFTA01036363.pdf

EFTA01184947Set 9

2016-03-033p717w

From: "jeffrey E." <jeevacation@gmail.com> To: Marc Rowan Subject: Re: TRA Valuation Process Date: Thu, 03 Mar 2016 22:38:03 +0000 Ask to see the worksheet with numbers On Thursday ... Marc Rowan < cmailto: Subject: RE: TRA Valuation Process Marc For purposes of establishing the balance sheet asset the DTA/TRA are undiscounted. Each period we re-assess our ability to realize ... Rowan Sent: Thursday, March 03, 2016 5:05 PM To: Chris Weidler Subject: Re: TRA Valuation Process This tells me what I already know. What rate do we discount future

https://www.justice.gov/epstein/files/DataSet%209/EFTA01184947.pdf

EFTA02366311Set 11

2013-05-142p278w

Alexanderson < Sent: Tuesday, May 14, 2013 8:22 PM To: jeeyacation@omail.com' Subject: Fw: 2010 TRA Payment From: Elliot Becker Sent: Tuesday, May 14, 2013 04:21 PM Eastern Standard Time ... Eileen Alexanderson Subject: Re: 2010 TRA Payment In 2015 as part of the 2014 tra payment. Elliot Becker On May 14, 2013, at 4:09 PM, "Eileen Alexanderson" < wrote: Hello ... will get paid in 2014 or in 2015 (as part of the 2014 TRA)? Thanks. From: Eileen Alexanderson Sent: Tuesday, May 14, 2013 3:32 PM To: 'Jeffrey Epstein' Subject

https://www.justice.gov/epstein/files/DataSet%2011/EFTA02366311.pdf

EFTA01088293Set 9

2015-06-041p224w

Effective Tax Rate (Per Management) 40.35% Discount Rate 12.00% (Smi!lions) Present Value of TRA Year TRA Amortization TRA Tax Shield Days PV Factor Tax Benefit ... Aggregate Present Value of TRA Tax Benefit, rounded $269,690.000 TRA Tax Benefit Sharing Percentage 85% Net Unrestricted TRA Tax Benefit Available to Block $229.236.500 Less: Restriction Period Discount (from ... Exhibit G-4) 15% ($34.385.475) Net Fair Market Value of TRA Tax Benefit Available to Block, rounded $195,000.000 EFTA01088293

https://www.justice.gov/epstein/files/DataSet%209/EFTA01088293.pdf

EFTA01217975Set 9

2015-06-1316p1,745w

iMessage 2015-06-13 15:45:04 UTC 4 Sender: Participants: ( ), Self ( e:jeeitunes@gmail.com ) Tra I know... It's beautiful iMessage [4] 2015-06-13 15:45:04 (UTC) Sender ... iMessage 2015-06-13 15:45:04 UTC 3 Sender: Participants: ( ), Self ( e:jeeitunes@gmail.com ) Tra I know... It's beautiful iMessage [3] 2015-06-13 15:45:04 (UTC) Sender ... iMessage 2015-06-13 15:45:04 UTC 1 Sender: Participants: ( ), Self ( jeeitunes®gmail.com ) Tra I know... It's beautiful iMessage

https://www.justice.gov/epstein/files/DataSet%209/EFTA01217975.pdf

EFTA00645429Set 9

2016-03-042p313w

From: Marc Rowan To: Jeffrey Epstein <jeevacation@gmail.com> Subject: Fwd: TRA Valuation Process Date: Fri, 04 Mar 2016 19:14:26 +0000 Attachments: ATT00001.htm; August_2015_AOG_B_Exchangen Detailed_Calculation.xlsx; ATT00002.htm ... Marc Rowan mailto: Cc: Martin Kell mailto: •>, Chris Weidler mailto: Subject: RE: TRA Valuation Process Marc — See attached calculation for an example of an AOG exchange ... Martin Kelly; Marc Rowan Cc: Suzanne Wong Subject: TRA Valuation Process Marc, Please see below for how the deferred tax asset (`DTA') and tax receivable agreement (`TRA') is calculated

https://www.justice.gov/epstein/files/DataSet%209/EFTA00645429.pdf