EFTA00621089Set 9
2010-04-197p2,032w
years through 2022 (the remaining life of the tax asset) and $1.9M of
imputed interest. The imputed interest results from discounting the $15.0M to $13.1M
and will ... Entities, as well as any Federal income tax
benefits realized from the Payments, including imputed interest, made pursuant to the
Tax Receivable Agreement.
APO Corp. expects to retain the remaining ... such a situation, the tax
rules require APO Corp. to calculate the "imputed interest" amount related to the portion
of the Payment that is deferred (i.e., the present value
https://www.justice.gov/epstein/files/DataSet%209/EFTA00621089.pdf
EFTA00621102Set 9
2007-07-1335p10,530w
provided for
certain arrangements with respect to the effect of the Basis Adjustment and Imputed Interest
(in each case, as defined herein) on the actual liability for Taxes ... exempted limited partnership, and BRH Holdings GP
Ltd., a Cayman Islands limited liability corporation.
"Imputed Interest" shall mean any interest imputed under Section 1272, 1274 or 483 or
other provision ... basis of the Original Assets and excluding
any deduction attributable to the Imputed Interest.
"Notes" has the meaning ascribed to such term in the Strategic Agreement.
"Objection Notice
https://www.justice.gov/epstein/files/DataSet%209/EFTA00621102.pdf
EFTA00589172Set 9
2007-07-1333p10,385w
provided for certain arrangements with respect to the effect of the
Basis Adjustment and Imputed Interest (in each case, as defined herein) on the actual liability for
Taxes ... exempted limited partnership, and BRH Holdings GP Ltd., a
Cayman Islands limited liability corporation.
"Imputed Interest" shall mean any interest imputed under Section 1272, 1274 or 483 or
other provision ... basis of the Original Assets and excluding any
deduction attributable to the Imputed Interest.
"Notes" has the meaning ascribed to such term in the Strategic Agreement.
"Objection Notice
https://www.justice.gov/epstein/files/DataSet%209/EFTA00589172.pdf
EFTA01084049Set 9
2007-07-1333p10,428w
provided for certain arrangements with respect to the effect of the
Basis Adjustment and Imputed Interest (in each case, as defined herein) on the actual liability for
Taxes ... exempted limited partnership, and BRH Holdings GP Ltd., a
Cayman Islands limited liability corporation.
"Imputed Interest" shall mean any interest imputed under Section 1272, 1274 or 483 or
other provision ... basis of the Original Assets and excluding any
deduction attributable to the Imputed Interest.
"Notes" has the meaning ascribed to such term in the Strategic Agreement.
"Objection Notice
https://www.justice.gov/epstein/files/DataSet%209/EFTA01084049.pdf
EFTA01127467Set 9
2007-07-135p1,864w
deductions (described above), and any income tax
benefits realized from the Payment, including imputed interest, resulting from the Tax Receivable
Agreement.
MO Corp. expects to benefit from the remaining ... such a situation, the tax
rules require APO Corp. to calculate the "imputed interest" amount related to the portion of the Payment
that is deferred (i.e., the present value ... made with respect to the current year tax
return). In 2007, the imputed interest amount is $240,680. This amount was calculated using the Applicable
Federal Rate ("AFR") which applied
https://www.justice.gov/epstein/files/DataSet%209/EFTA01127467.pdf
EFTA00624765Set 9
2012-12-316p727w
Benefit Payment (includes Imputed Interest under IRC Section 483) 30 369 047
!RC Section 483 Imputed Interest (installment sale rules) 7,611,137
Section 483 Interest Rate ... Standalone APO Corp Income ($502) (5502)
Section 197 Amortization (69,853,985)
Sec 483 Imputed Interest (1,231,680)
Interest Expense on Late Payment (8,038)
Net Operating Loss Carryforward ... basis of the Original
Assets and excluding any deduction attributable to the Imputed Interest.
5o46
EFTA00624769
Apollo Global Management, LLC
TRA Late Payment Interest Calculation
December 31 2012
Tax Benefit
https://www.justice.gov/epstein/files/DataSet%209/EFTA00624765.pdf
EFTA01076062Set 9
2011-02-266p710w
Realized Tax Benefit 81.025.252
3.01(b) 85% Per TRA 85%
Tax Benefit Payment (includes Imputed Interest under IRC
3.01(b) Section 483) $ 51.871.484
IRC Section 483 Imputed Interest (installment sale ... Corp Income ($494,864) ($494,864)
Section 197 Amortization (65,898,090)
Sec 483 Imputed Interest Related to 754 election (1,871,766)
Interest Expense on Late Payment ... basis of the C
Assets and excluding any deduction attributable to the Imputed Interest.
5 of 6
EFTA01076066
APO Corp Related Taxable Income
TRA Late Payment Interest Amount Calculation
https://www.justice.gov/epstein/files/DataSet%209/EFTA01076062.pdf
EFTA01110636Set 9
2011-12-316p736w
Realized Tax Benefit 8.823.687
3.01(0) 85% Per TRA 65%
Tax Benefit Payment (includes Imputed Interest under
3.01(0) IRC Sentinel 483) 5.800.134
IRC Section 483 invited Interest (installment sate ... Corp Income ($13,508) ($13,508)
Section 197 Amortization (68,630,497)
Sec 483 Imputed Interest (8,845,928)
Interest Expense on Late Payment (41,787)
Net Operating Loss
Charity ... basis of the Original
Assets and excluding any deduction attributable to the Imputed Interest.
5 of 6
EFTA01110640
APO Corp Related Taxable Income
TRA Late Payment Interest Amount Calculation
https://www.justice.gov/epstein/files/DataSet%209/EFTA01110636.pdf
EFTA00621096Set 9
2010-04-196p568w
Realized Tax Benefit 17.654.514
3.01(b) 85% Per TRA 85%
Tax Benefit Payment (includes Imputed Interest wider IRC
3.01(b) Section 483) 15.006.337
IRC Section 483 Imputed Interest (Instalment sale ... Amortization (65,198,441) 65,198,441
Sec 483 Imputed Interest Related to 754 election (1,266,097) 1,266,097
Interest Expense on Late Payment
https://www.justice.gov/epstein/files/DataSet%209/EFTA00621096.pdf
EFTA01746658Set 10
2015-02-241p260w
Brad Wechsler
To: Ada Clapp , Eileen Alexanderson
Cc: Jeffrey Epstein <jeevacation©gmail.com>
Subject: Re: Imputed interest on intra-family notes
Sent: Tuesday, February ... Date: Tue, 24 Feb 2015 16:06:32
To: Brad Wechsler Eileen Alexanderson<
Subject: Imputed interest on intra-family notes
I think JEE was asking solely about interest imputed
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01746658.pdf
EFTA00869478Set 9
2014-09-184p794w
free loan from a grantor trust to a beneficiary may subject the grantor to
imputed interest under Section 7872.
EFTA00869478
As you know, with a grantor trust, under ... loan is a form of distribution to the beneficiary in the
amount of the imputed interest. Distributions from grantor trusts, as you know, have no income tax
consequences. However ... grantor trust is the lender, the
grantor would be subject to income tax on imputed interest.
Alan S. Halperin I Partner
Paul, Weiss, Rifkind, Wharton & Garrison LLP
1285 Avenue
https://www.justice.gov/epstein/files/DataSet%209/EFTA00869478.pdf
EFTA00869482Set 9
2014-09-184p793w
free loan from a grantor trust to a beneficiary may subject the grantor to
imputed interest under Section 7872.
EFTA00869482
As you know, with a grantor trust, under ... loan is a form of distribution to the beneficiary in the
amount of the imputed interest. Distributions from grantor trusts, as you know, have no income tax
consequences. However ... grantor trust is the lender, the
grantor would be subject to income tax on imputed interest.
Alan S. Halperin I Partner
Paul, Weiss, Ftificind, Wharton & Garrison LLP
1285 Avenue
https://www.justice.gov/epstein/files/DataSet%209/EFTA00869482.pdf
EFTA00678131Set 9
2014-09-182p713w
free loan from a grantor trust to a beneficiary may subject the grantor to imputed interest under Section
7872.
As you know, with a grantor trust, under 671, the grantor ... loan is a form of distribution to the beneficiary in the amount
of the imputed interest. Distributions from grantor trusts, as you know, have no income tax consequences. However ... grantor trust is the lender, the grantor
would be subject to income tax on imputed interest.
EFTA00678131
Alan S. Halperin I Partner
Paul, Weiss, Rifkind, Wharton & Garrison LLP
1285 Avenue
https://www.justice.gov/epstein/files/DataSet%209/EFTA00678131.pdf
Cargometrics Technologies LLC •
Partnership • S. Borgerson 0
Imputed Interest Terramar 24,164
Other • Adjustment (4) (4) (4) (4)
Capital Gain (Loss) (B) 109,075 109,075
Limitation Adjustment
TOTAL ... Cargometrics Technologies LLC •
Partnership- (166,783) (166,783) 168 (166,951) (166,783)
Imputed Interest Terramar 18,889 18,889
Other • Adjustment 136 136
Capital Gain (Loss
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01655019.pdf