EFTA00584463.txt

"The Taxpayers own interests in a wide variety of entities related to Apollo Global Management, LLC ("Apollo") ... through their interest in BRH Holdin"

"The Taxpayers own interests in a wide variety of entities related to Apollo Global Management, LLC ("Apollo") ... through their interest in BRH Holdin"

"Deloitte (Apollo's tax advisor)"

"The Foreign Entities, other than BRH and AP Professional Holdings LP, are also owned, in part, indirectly by Apollo."

"the accompanying International Information Returns were prepared by the Taxpayers' professional accountants at Raich Ende Malter & Co. LLP"

"the accompanying International Information Returns were prepared by the Taxpayers' professional accountants at Raich Ende Malter & Co. LLP"

"diligently reviewed the history and factual circumstances with their accountants and the law firm of Paul, Weiss, Rifkind, Wharton & Garrison LLP"

"diligently reviewed the history and factual circumstances with their accountants and the law firm of Paul, Weiss, Rifkind, Wharton & Garrison LLP"