investment in the Access Fund. This discussion is based upon the Code, existing U.S.
Treasury Regulations, and judicial decisions and administrative interpretations thereunder, all as of the date
of this ... decisions of the trust or (ii) has a valid election in effect under applicable U.S. Treasury Regulations to be
treated as a U.S. person. If an entity treated
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EFTA02718253Set 11
2014-08-265p1,219w
delete the material from
any computer.
Apollo Global Management, LLC
Pursuant to U.S. Treasury regulations, any federal tax advice contained in =his communication, including attachments
and enclosures, is not intended ... keting, or recommending to another party any tax-
related matters addressed=herein.
Pursuant to U.S. Treasury regulations, any federal tax advice contained in =his communication, including attachments
and enclosures
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Partnership Agreement
Notwithstanding anything in this Memorandum to the contrary, to
comply with U.S. Treasury Regulations Section 1.6011-41(6)(3)(i), each
investor (and any employee, representative, or other
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