Epstein Files Search

EFTA01047851Set 9

2017-04-303p1,362w

that other execs at Apollo also received assessments, it's highly likely that the BRH adjustment resulted from an audit of entities downstream from BRH. What I don't know ... extend statute would be requested on an audit such as the one involving BRH and related entities. From: Barry J. Cohen [mato: Sent: Sunday, April ... Leon Black Subject: IRS Maybe there was an audit of an entity downstream from BRH. I only asked Apollo about BRH. How else would 2012 still be open? Sent from

https://www.justice.gov/epstein/files/DataSet%209/EFTA01047851.pdf

EFTA01047854Set 9

2017-05-013p1,408w

closed? 3. Have they been interacting with the designated tax partner at brh or anyone else at apollo? 4. Are we correct in assuming that this "assessment" moots their first ... their own initial question to leon? For apollo: I. Have other people been receiving brh assessments. 2. Do they foot with our (apollo's) records of brh ownership ... Leon Black Subject: IRS Maybe there was an audit of an entity downstream from BRH. I only asked Apollo about BRH. How else would 2012 still be open? Sent from

https://www.justice.gov/epstein/files/DataSet%209/EFTA01047854.pdf

EFTA01047857Set 9

2017-05-013p1,461w

closed? 3. Have they been interacting with the designated tax partner at brh or anyone else at apollo? 4. Are we correct in assuming that this "assessment" moots their first ... their own initial question to leon? For apollo: I. Have other people been receiving brh assessments. 2. Do they foot with our (apollo's) records of brh ownership ... Leon Black Subject: IRS Maybe there was an audit of an entity downstream from BRH. I only asked Apollo about BRH. How else would 2012 still be open? Sent from

https://www.justice.gov/epstein/files/DataSet%209/EFTA01047857.pdf

EFTA00582847Set 9

2013-06-193p1,383w

Principals have in their limited partnership interests in AMH (through their ownership of BRH and AP Professional). The plan is only effective if all 3 Principals participate fully. Proposed Plan ... same proportion of $800m as the proportions in which the principals currently own BRH. The total capital of all the SPVs would be no less than $800m. The proportion ... factors. The SPV borrowing would be secured by the preferred interests in BRH discussed in paragraph 3, and could be guaranteed as to their respective SPV by the owner/Principal

https://www.justice.gov/epstein/files/DataSet%209/EFTA00582847.pdf

EFTA01047848Set 9

2017-04-303p1,226w

Maybe there was an audit of an entity downstream from BRH. I only asked Apollo about BRH. How else would 2012 still be open? Sent from my iPhone ... sometimes does examinations internally (client isn't contacted until "internal" audit is concluded).. Because BRH Holdings LP is mainly a holding entity owning many other flow-through partnership entities ... could easily trace all K-1's flowing from these other partnerships to the BRH return without doing a field audit at Apollo's offices. It would not be difficult

https://www.justice.gov/epstein/files/DataSet%209/EFTA01047848.pdf

EFTA02705481Set 11

2007-07-1312p4,960w

also terminate receive Mr. Black's equity in for certain bad acts by Mr. BRH Holdings GP automatically Black, if it arose due to Mr. (AAP §5.1(a)). Black ... professionals besides Principals (§4.2(b)). 3. Veto over the dissolution of BRH Holdings or other acts 3. Right to be one of the two required Principal votes needed that would ... Inspection/information rights for matters related to Mr. Black's interest in BRH Holdings, L.P. (O.7). 1. Right to approve the dissolution of BRH Holdings, L.P. or any 1. Cause exchanges

https://www.justice.gov/epstein/files/DataSet%2011/EFTA02705481.pdf

EFTA01969636Set 10

2013-06-195p1,549w

prineipalsPrincipals have in their limited partnership interestinterests in AMH (through their ownership of BRH and AP Professional). The sirewman-is-a-basis-fer-farther- diseussion-and-refinementr-Titere ... same proportion of $800m as the proportions in which the principals currently own BRH. The total capital of all the SPVs would be no less than $800m. The proportion ... factors. The SPV borrowing would be secured by the preferred AMH-interestinterests in BRH discussed in paragraph 3, and could be guaranteed as to their respective SPV by the pritteipalsoaigairjul

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01969636.pdf

EFTA00838368Set 9

2018-04-0867p54,266w

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 13 . gifts ... 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 13 . gifts ... 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 13 . gifts

https://www.justice.gov/epstein/files/DataSet%209/EFTA00838368.pdf

EFTA02651276Set 11

2017-04-304p1,195w

sometimes does examinations internally (client isn't contacted until "internal" audit is concluded).. Because BRH Holdings LP is mainly a holding entity owning many other flow-through partnership entities ... could easily trace all K-1's flowing from these other partnerships to the BRH return without doing a field audit at Apollo's offices. It would not be difficult ... undertake such an internal audit and trace all the K-1's into BRH. The IRS could readily pull this K-1 information from their system. It is very surprising

https://www.justice.gov/epstein/files/DataSet%2011/EFTA02651276.pdf

EFTA00812184Set 9

102p54,227w

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 13 . gifts ... 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 13 . gifts ... 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 13 . gifts

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

EFTA01047845Set 9

2017-04-303p1,183w

sometimes does examinations internally (client isn't contacted until "internal" audit is concluded).. Because BRH Holdings LP is mainly a holding entity owning many other flow-through partnership entities ... could easily trace all K-1's flowing from these other partnerships to the BRH return without doing a field audit at Apollo's offices. It would not be difficult ... undertake such an internal audit and trace all the K-1's into BRH. The IRS could readily pull this K-1 information from their system. It is very surprising

https://www.justice.gov/epstein/files/DataSet%209/EFTA01047845.pdf

EFTA00584470Set 9

7p1,720w

Global Management, LLC ("Apollo"), the publicly traded alternative asset manager, through their interest in BRH Holdings, L.P. (EIN: 98-0541994) ("BRH" or the "Partnership"). Since the inception ofBRH, employees ... Apollo have assisted with the preparation of the tax returns of BRH as well as all but three of the other controlled foreign partnerships, controlled foreign corporations and foreign disregarded ... Foreign Entities") listed on the enclosed Exhibit A. The Foreign Entities related to BRH, other than AP Professional Holdings LP, are also owned, in part, indirectly by Apollo. The appropriate

https://www.justice.gov/epstein/files/DataSet%209/EFTA00584470.pdf

EFTA00584477Set 9

6p1,522w

Global Management, LLC ("Apollo"), the publicly traded alternative asset manager, through their interest in BRH Holdings, L.P. (EIN: 98-0541994) ("BRH" or the "Partnership"). Since the inception ofBRH, employees ... Apollo have assisted with the preparation of the tax returns of BRH as well as all but two of the other controlled foreign partnerships, controlled foreign corporations and foreign disregarded ... Foreign Entities") listed on the enclosed Exhibit A. The Foreign Entities related to BRH, other than AP Professional Holdings LP, are also owned, in part, indirectly by Apollo. The appropriate

https://www.justice.gov/epstein/files/DataSet%209/EFTA00584477.pdf

EFTA00590604Set 9

2017-01-087p1,350w

Global Management, LLC ("Apollo"), the publicly traded alternative asset manager, through their interest in BRH Holdings, M. (EIN: 98-0541994) ("BRH" or the "Partnership"). The Taxpayers became partners in BRH ... employees of Apollo have assisted with the preparation of the tax returns of BRH as well as all but two of the other controlled foreign partnerships, controlled foreign corporations ... enclosed Exhibit A. The Taxpayers-were-previded-with-a-Foreim Entities related to BRH are also owned, in part, indirectly by Apollo. The appropriate Apollo entities timely and properly filed

https://www.justice.gov/epstein/files/DataSet%209/EFTA00590604.pdf

EFTA01047808Set 9

2017-04-302p865w

example, josh h's number and know his and leon's relative ownership % of brh in 2012 and the math is simple. I really think the obvious next step ... CONFIDENTIAL Here are my observations: 1. The first IRS letter references a "review" of BRH, but doesn't suggest that there will be changes to the BRH K-1 items ... original). It asks what K-1 LDB used because it can't find the BRH K-1 or its exact numbers on LDB's return. 2. The second IRS letter

https://www.justice.gov/epstein/files/DataSet%209/EFTA01047808.pdf

EFTA02651844Set 11

2017-04-302p868w

example, josh h's number and know his and leon's relative ownership % of brh in 2012 and the math is simple. I really think the obvious next step ... CONFIDENTIAL Here are my observations: 1. The first IRS letter references a "review" of BRH, but doesn't suggest that there will be changes to the BRH K-1 items ... original). It asks what K-1 LDB used because it can't find the BRH K-1 or its exact numbers on LDB's return. 2. The second IRS letter

https://www.justice.gov/epstein/files/DataSet%2011/EFTA02651844.pdf

EFTA00584493Set 9

5p1,290w

Global Management, LLC ("Apollo"), the publicly traded alternative asset manager, through their interest in BRH Holdings, L.P. (EIN: 98-0541994) ("BRH" or the "Partnership"). The Taxpayers became partners in BRH ... Foreign Entities") listed on the enclosed Exhibit A. The Foreign Entities related to BRH, other than AP Professional Holdings LP, are also owned, in part, indirectly by Apollo. The appropriate ... indicate any obligation to file the International Information Returns with respect to BRH or the many other Foreign Entities held through BRH. In addition, the Foreign Entities related to BRH

https://www.justice.gov/epstein/files/DataSet%209/EFTA00584493.pdf

EFTA00584488Set 9

5p1,340w

Global Management, LLC ("Apollo"), the publicly traded alternative asset manager, through their interest in BRH Holdings, L.P. (EIN: 98-0541994) ("BRH" or the "Partnership"). Since the inception ofBRH, employees ... Apollo have assisted with the preparation of the tax returns of BRH as well as all but two of the other controlled foreign partnerships, controlled foreign corporations and foreign disregarded ... Foreign Entities") listed on the enclosed Exhibit A. The Foreign Entities related to BRH, other than AP Professional Holdings LP, are also owned, in part, indirectly by Apollo. The appropriate

https://www.justice.gov/epstein/files/DataSet%209/EFTA00584488.pdf

EFTA00669234Set 9

2017-04-302p725w

LDB_Tax_notice_RE_2012.pdf Here are my observations: 1. The first IRS letter references a "review" of BRH, but doesn't suggest that there will be changes to the BRH K-1 items ... original). It asks what K-1 LDB used because it can't find the BRH K-1 or its exact numbers on LDB's return. 2. The second IRS letter ... indicates an adjustment of $884,006, referencing 98-054199, which is BRH's TIN; not to mention the p. 10 footnote which mentions BRH. 3. I'm not sure

https://www.justice.gov/epstein/files/DataSet%209/EFTA00669234.pdf

EFTA01047805Set 9

2017-04-302p866w

Black Here are my observations: I. The first IRS letter references a "review" of BRH, but doesn't suggest that there will be changes to the BRH K-1 items ... original). It asks what K-1 LDB used because it can't find the BRH K-1 or its exact numbers on LDB's return. 2. The second IRS letter ... indicates an adjustment of $884,006, referencing 98-054199, which is BRH's TIN; not to mention the p. 10 footnote which mentions BRH. 3. not sure

https://www.justice.gov/epstein/files/DataSet%209/EFTA01047805.pdf