📄 Extracted Text (7,638 words)
LEON D. BLACK -SS NO.
SCHEDULE OF TAXABLE GIFTS MADE TO THE
JUDAH INVESTMENTS TRUSTS (A THRU K) - DEC 21, 2006
GRANTOR RETAINED ANNUITY TRUSTS
December 2006 (6.8%) year annuity Percent annuity amount
1 49.5683% $ 290,175,433.68
TOTAL FOR ALL 2 59.4820% $ 348,210,520.41
DECEMBER GRATS: 99.9900% $ 585,346,794.47
$ 585,405,335.00 Initial FMV of trust
$ 585,346,794.47 retained interest 99 99%
68,640.63 taxable glft 001%
100 00%
Initial FMV of Trust Fund
$ 460,000.00 Apollo Management III„ LP
1,420,000.00 Apollo Management IV, LP
3,690,000.00 Apollo Management V. LP
$ 45,600,000.00 Apollo Management VI, LP
$ 227,000,000.00 Apollo Investment Management, LP
9,600,000.00 Apollo Value Inv Fund Mgt., LP
$ 87,000,000.00 Apollo SVF Management. LP
$ 20,800,000.00 Apollo Asia Management LP
$ 98,800,000.00 Apollo Europe Management LP
$ 80,500,000.00 Apollo Alternative Assets LP
$ 10,535,335.00 Apollo Adv VI LP & Apollo Adv. VI (EH) LP
$ 585,405,335.00 TOTAL
Judah Investment Trust A
December 2006 (5.8%)
year annuity percent annuity amount
1 49.5683% $ 228,014.15
2 59.4820% $ 273,616.98
99.9900% $ 459 954.00
460,000.00 initial FMV of trust
459,954.00 retains interest
$ 46.00 taxable gift
S 460.000.00 appraised value of 30.35% interest in Apollo Management III LP
EFTA01127743
•
LEON D. BLACK - SS NO
SCHEDULE OF TAXABLE GIFTS MADE TO THE
JUDAH INVESTMENTS TRUSTS (A THRU K) - DEC 21, 2006
GRANTOR RETAINED ANNUITY TRUSTS (CONTINUED) PG 2 OF 6
Judah Investment Trust B
December 2006 (5.8%)
year annuity Percent annuity amount
1 49.5683% $ 703.869.77
2 59.4820% $ 844.64172
99.9900% $ 1.419.858.00
1,420,000.00 initial FMV of trust
1,419,858.00 retained interest
142.00 taxable gift
1.420,000.00 appraised value of 30.35% Interest in Apollo Management IV, LP
Judah Investment Trust C
December 2006 (5.8%)
year annuity percent annuity amount
1 49.5683% $ 1,829.070.02
2 59.4820% $ 2.194.884.03
99.9900% $ 3.889.631.00
3,690,000.00 initial FMV of trust
3,689,631.00 retained interest
S 369.00 taxable gift
3,690.000.00 appraised value of 30.35% interest in Apollo Management V. LP
Judah Investment Trust
December 2006 (5.8%)
year annuity percent annuity amount
1 49.5883% $ 22,603,141.76
2 59.4820% $ 27,123,770.12
99.9900% $ 45.595.440.00
S 45,600.000.00 initial FMV of trust
S 45.595.440.00 retained interest
4,560.00 taxable gift
45.600.000.00 appraised value of 30.35% interest in Apollo Management VI, LP
EFTA01127744
LEON D. BLACK - SS NO
SCHEDULE OF TAXABLE GIFTS MADE TO THE
JUDAH INVESTMENTS TRUSTS (A THRU K) - DEC 21, 2006
GRANTOR RETAINED ANNUITY TRUSTS (CONTINUED) PG 3 OF 5
Judah Investment Trust E
Decanter 2006 (5.8%)
year annuity percent annuity amount
1 49.5683% $ 112,520.025.88
2 59.4620% $ 135,024,031.06
99.9900% $ 226,977,300.00
$ 227,000,000.00 initial FMV of trust
S 226,977,300.00 retained interest
22,700.00 taxable gift
227,000,000.00 appraised value of 26.8% interest in Apollo Investment Management, LP
Judah Investment Trust F
December 2006 (5.8%)
year annuity percent annuity amount
1 49.5683% $ 4.758.556.16
2 59.4820% $ 5,710,267.39
99.9900% $ 9.599.040.00
9,600,000.00 initial FMV of trust
9,599,040.00 retained interest
960.00 taxable gift
$ 9,600,000.00 appraised value of 26.9% interest in Apollo Value Investment Fund Management, LP
Judah Investment Trust G
December 2006 (5 8%)
year annuity percent annuity amount
1 49.5683% $ 43.124.415.21
2 59.4820% $ 51,749,298.25
99.9900% $ 86,991,300.00
$ 87,000,000.00 initial FMV of trust
S 86,991,300.00 retained interest
8,700.00 taxable gift
S 87,000,000 00 appraised value of 44% interest in Apollo SVF Management, LP
EFTA01127745
0
LEON D. BLACK - SS NO
SCHEDULE OF TAXABLE GIFTS MADE TO THE
JUDAH INVESTMENTS TRUSTS (A THRU K) - DEC 21, 2006
GRANTOR RETAINED ANNUITY TRUSTS (CONTINUED) PG 4 OF 6
Judah Investment Trust H
December 2006 (5.8%)
year annuity percent annuity amount
1 49.5683% $ 10.310.205.01
2 59.4820% $ 12,372,246.02
99.9900% $ 20,797 920.00
$ 20,800,000.00 initial FMV of trust
$ 20,797,920.00 retained interest
$ 2,080.00 taxable gift
$ 20,800,000.00 appraised value of 44% interest in Apollo Asia Management, LP
Judah Investment Trust I
December 2006 (5.8%)
year annuity percent annuity amount
1 49.6683% $ 48,973,473.82
2 59.4820% $ 58,768,168.58
99.9900% $ 98,790,120.00
$ 98,800,000.00 initial FMV of trust
$ 98,790,120.00 retained Interest
9,880.00 taxable gift
$ 98,800,000.00 appraised value of 44% intorest in Apollo Europe Management, LP
Judah Investment Trust J
December 2008 (5 8%)
year annuity percent annuity amount
1 49.5683% $ 39,902,476.14
2 59.4820% $ 47,882,971.37
99.9900% $ 80,491,950.00
80,500,000.00 initial FMV of trust
80,491,950.00 retained interest
8,080.00 taxable gift
$ 80,500,000.00 appraised value of 44% interest in Apollo Alternative Assets, LP
EFTA01127746
LEON D. BLACK - SS NO
SCHEDULE OF TAXABLE GIFTS MADE TO THE
JUDAH INVESTMENTS TRUSTS (A THRU K) - DEC 21, 2006
GRANTOR RETAINED ANNUITY TRUSTS (CONTINUED) PG 5 OF S
Judah Investment Trust K
December 2006 (5.8%)
year annuity percent annuity amount
1 49.5683% $ 5,222,185.76
2 59.4820% $ 6,266,622.91
99.9900% $ 10 534 281 47
10,535,335.00 initial FMV of trust
10,634,281.47 retained interest
1,053.63 taxable gift
$ 10,535.335.00 142 Points of Apollo Advisors VI and Apollo Advisors VI (EH)
EFTA01127747
LEON D. BLACK
Rider I to Form 709
United States Gift and Generation Skipping Transfer Tax Return
Calendar Year 2006
Social Security No.
Disclosure Pursuant to Regulation Section 301.6501(c)-I (f)(2)
CONTRIBUTION TO JUDAH INVESTMENT TRUST A (Sch. A, Part 3, Item 11
The transaction referred to as Item 1 on Schedule A, Part 3 of this Return represents the
contribution by Leon D. Black (the "Taxpayer") to the Judah Investment Trust A (the
'Trust"), created under trust agreement dated December 21, 2006 (the "Trust Creation Date")
between Leon D. Black, as senior, and Leon D. Black and John Hannan, as trustees (the
"Trust Agreement"). The Trust is a grantor-retained annuity trust in which the Taxpayer
retained a Qualified Interest,.._asAefinecLia..§.2102(h) of the_IntemaLatienie_Qt(the
"Code"). A copy of the Trust Agreement is attached as Exhibit G-I.
Under the terms of the Trust Agreement, an annuity is payable from the Trust to the
Taxpayer (or, if the Taxpayer is not living, to the Taxpayer's estate) on the day before the
first anniversary of the Trust Creation Date, and on the day before the 2nd and final
anniversary of the Trust Creation Date during the Trust's 2-year term. The value of the first
annuity is equal to such percent of the fair market value of the trust fund of the Trust as
finally determined for federal gift tax purposes that, when increased by twenty (20%) percent
in the 2nd and final year of the 2-year term, results in the Taxpayer's right to receive the
annuity payments having a value equal to 99.99% of the fair market value of the trust fund of
the Trust as finally determined for federal gift tax purposes. The value of the second and
final annuity payable to the Taxpayer is equal to 120% of the value of the prior year's
annuity. The Trust ends on the day before the 2nd anniversary of the Trust Creation Date.
Upon the termination of the Trust, the remaining trust property will be distributed to the
trustees of the Black 2006 Family Trust (the "Family Trust"), to be added to the principal of
the Family Trust and disposed of therewith.
The value of the gift is determined by subtracting the value of the qualified annuity interest
from the value of the property contributed to the Trust. Under Treas. Reg. § 25.2702-2(b)(2),
the value of a qualified annuity interest is determined under Code § 7520.
Accordingly, for the transfer shown as Item 1 of Schedule A, Part 3 of the Return, there is
shown below (I) the valuation of the initial fair market value of the Trust, (2) the annuity
percentages taken from the Trust Agreement, (3) the annuity term taken from the Trust
Agreement, (4) the § 7520 rate in effect for the month in which the transfers occurred, (5) the
value of the qualified annuity and (6) the resulting gift.
NYIA1320433101194.69011DOa2650/0001
EFTA01127748
On December 21, 2006, the Taxpayer contributed to the Trust a 30.35% limited partnership
interest in Apollo Management III, LP, a Delaware limited partnership. The Taxpayer
received no consideration from the Trust in return for his contribution. Based on an appraisal
by Empire Valuation Consultants., a copy of which is attached as Exhibit G- I AP, on
December 21, 2006 the gift tax value of the 30.35% limited partnership interest in Apollo
Management III, LP the Taxpayer transferred to the Trust was $460,000.
(1) Initial Fair Market Value of the Trust Fund $460,000
(2) Annuity Rate Per Trust Agreement: 49.5683% in year 1; 59.4820% in
year 2
(3) Annuity Term Per Trust Agreement 2 Years
(4) Section 7520 Rate for Dec 2006 5.8%
(5) Value of Qualified Annuity $459,954
(6) Value of Gift $46.00
NV1:1151043901\WL6901!-D0O2650.1.0001 2
EFTA01127749
LEON D. BLACK
Rider I to Form 709
United States Gift and Generation Skipping Transfer Tax Return
Calendar Year 2006
Social Security No.-
Disclosure Pursuant to Regulation Section 301.6501(c)-I (0(2)
CONTRIBUTION TO JUDAFI INVESTMENT TRUST B (Sch. A, Part 3, Item 1)
The transaction referred to as Item 1 on Schedule A, Part 3 of this Return represents the
contribution by Leon D. Black (the "Taxpayer") to the Judah Investment Trust B (the
"Trust"), created under trust agreement dated December 21, 2006 (the "Trust Creation Date")
between Leon D. Black, as settlor, and Leon D. Black and John Harman, as trustees (the
"Trust Agreement"). The Trust is a grantor-retained annuity trust in which the taxpayer
_02(b)_a_the_IntemaLRevenue Code4the
"Code"). A copy of the Trust Agreement is attached as Exhibit G-2.
Under the terms of the Trust Agreement, an annuity is payable from the Trust to the
Taxpayer (or, if the Taxpayer is not living, to the Taxpayer's estate) on the day before the
first anniversary of the Trust Creation Date, and on the day before the 2nd and final
anniversary of the Trust Creation Date during the Trust's 2-year term. The value of the first
annuity is equal to such percent of the fair market value of the trust fund of the Trust as
finally determined for federal gift tax purposes that, when increased by twenty (20%) percent
in the 2nd and final year of the 2-year term, results in the Taxpayer's right to receive the
annuity payments having a value equal to 99.99% of the fair market value of the trust fund of
the Trust as finally determined for federal gift tax purposes. The value of the second and
final annuity payable to the Taxpayer is equal to 120% of the value of the prior year's
annuity. The Trust ends on the day before the 2nd anniversary of the Trust Creation Date.
Upon the termination of the Trust, the remaining trust property will be distributed to the
trustees of the Black 2006 Family Trust (the "Family Trust"), to be added to the principal of
the Family Trust and disposed of therewith.
The value of the gift is determined by subtracting the value of the qualified annuity interest
from the value of the property contributed to the Trust. Under Treas. Reg. § 25.2702-2(b)(2),
the value of a qualified annuity interest is determined under Code § 7520.
Accordingly, for the transfer shown as Item 1 of Schedule A, Part 3 of the Return, there is
shown below (1) the valuation of the initial fair market value of the Trust, (2) the annuity
percentages taken from the Trust Agreement, (3) the annuity term taken from the Trust
Agreement, (4) the § 7520 rate in effect for the month in which the transfers occurred, (5) the
value of the qualified annuity and (6) the resulting gift.
NY I Al 52043701AWL6901100026504.000 I
EFTA01127750
•
On December 21,.2006, the Taxpayer contributed to the Trust a 30.35% limited partnership
interest in Apollo Management IV LP, a Delaware limited partnership. The Taxpayer
received no consideration from the Trust in return for his contribution. Based on an appraisal
by Empire Valuation Consultants., a copy of which is attached as Exhibit G-2AP, on
December 21, 2006 the gift tax value of the 30.35% limited partnership interest in Apollo
Management IV, LP the Taxpayer transferred to the Trust was 51,420,000.
(I) Initial Fair Market Value of the Trust Fund $1,420,000
(2) Annuity Rate Per Trust Agreement: 49.5683% in year 1; 59.4820% in
year 2
(3) Annuity Term Per Trust Agreement 2 Years
(4) Section 7520 Rate for December 2006 5.8%
(5) Value of Qualified Annuity $1,419,858
(6) Value of Gift $142.00
NYIA152041MINWL690P.DOO26504.0001 2
EFTA01127751
LEON D. BLACK
Rider 1 to Form 709
United States Gift and Generation Skipping Transfer Tax Return
Calendar Year 2006
Social Security No
Disclosure Pursuant to Regulation Section 301.6501(c)-1(O(2)
CONTRIBUTION TO JUDAH INVESTMENT TRUST C (Sch. A, Part 3, Item It
The transaction referred to as Item I on Schedule A, Part 3 of this Return represents the
contribution by Leon D. Black (the "Taxpayer") to the Judah Investment Trust C (the
"Trust"), created under trust agreement dated December 21, 2006 (the "Trust Creation Date")
between Leon D. Black, as senior, and Leon D. Black and John Hannan, as trustees (the
"Trust Agreement"). The Trust is a grantor-retained annuity trust in which the Taxpayer
retained ratified Interest efined in § 2702(b) of the Internal Revenue Code (the
"Code"). A copy of the Trust Agreement is attached as Exhibit G-3.
Under the terms of the Trust Agreement, an annuity is payable from the Trust to the
Taxpayer (or, if the Taxpayer is not living, to the Taxpayer's estate) on the day before the
first anniversary of the Trust Creation Date, and on the day before the 2nd and final
anniversary of the Trust Creation Date during the Trust's 2-year term. The value of the first
annuity is equal to such percent of the fair market value of the trust fund of the Trust as
finally determined for federal gift tax purposes that, when increased by twenty (20%) percent
in the 2nd and final year of the 2-year term, results in the Taxpayer's right to receive the
annuity payments having a value equal to 99.99% of the fair market value of the trust fund of
the Trust as finally determined for federal gift tax purposes. The value of the second and
final annuity payable to the Taxpayer is equal to 120% of the value of the prior year's
annuity. The Trust ends on the day before the 2nd anniversary of the Trust Creation Date.
Upon the termination of the Trust, the remaining trust property will be distributed to the
trustees of the Black 2006 Family Trust (the "Family Trust"), to be added to the principal of
the Family Trust and disposed of therewith.
The value of the gift is determined by subtracting the value of the qualified annuity interest
from the value of the property contributed to the Trust. Under Treas. Reg. § 25.2702-2(6)(2),
the value of a qualified annuity interest is determined under Code § 7520.
Accordingly, for the transfer shown as Item 1 of Schedule A, Part 3 of the Return, there is
shown below (1) the valuation of the initial fair market value of the Trust, (2) the annuity
percentages taken from the Trust Agreement, (3) the annuity term taken from the Trust
Agreement, (4) the § 7520 rate in effect for the month in which the transfers occurred, (5) the
value of the qualified annuity and (6) the resulting gift.
NY I AlS204331015W1.6901100026504.0001
EFTA01127752
On December 21, 2006, the Taxpayer contributed to the Trust a 30.35% limited partnership
interest in Apollo Management V, LP, a Delaware limited partnership. The Taxpayer
received no consideration from the Trust in return for his contribution. Based on an appraisal
by Empire Valuation Consultants., a copy of which is attached as Exhibit G-3AP, on
December 21, 2006 the gift tax value of the 30.35% limited partnership interest in Apollo
Management V, LP the Taxpayer transferred to the Trust was $3,690,000.
(1) Initial Fair Market Value of the Trust Fund $3,690,000
(2) Annuity Rate Per Trust Agreement: 49.5683% in year 1; 59.4820% in
year 2
(3) Annuity Term Per Trust Agreement 2 Years
(4) Section 7520 Rate for December 2006 5.8%
(5) Value of Qualified Annuity $3,689,631.00
(6) Value of Gift $369.00
NYIMS10433101W/14901100026504.0001 2
EFTA01127753
0
LEON D. BLACK
Rider 1 to Form 709
United States Gift and Generation Skipping Transfer Tax Return
Calendar Year 2006
Social Security No
Disclosure Pursuant to Regulation Section 301.6501(c)-1(f)(2)
CONTRIBUTION TO JUDAH INVESTMENT TRUST D (Sch. A, Part 3, Item I)
The transaction referred to as Item 1 on Schedule A, Part 3 of this Return represents the
contribution by Leon D. Black (the "Taxpayer") to the Judah Investment Trust D (the
"Trust"), created under trust agreement dated December 21, 2006 (the "Trust Creation Date")
between Leon D. Black, as settlor, and Leon D. Black and John Hannan, as trustees (the
"Trust Agreement"). The Trust is a grantor-retained annuity trust in which the Taxpayer
retained a Qualified_ as deftmed in § 2702(b) of the Internal Revenue Code (the
"Code"). A copy of the Trust Agreement is attached as Exhibit G-4.
Under the terms of the Trust Agreement, an annuity is payable from the Trust to the
Taxpayer (or, if the Taxpayer is not living, to the Taxpayer's estate) on the day before the
first anniversary of the Trust Creation Date, and on the day before the 2nd and final
anniversary of the Trust Creation Date during the Trust's 2-year term. The value of the first
annuity is equal to such percent of the fair market value of the trust fund of the Trust as
finally determined for federal gift tax purposes that, when increased by twenty (20%) percent
in the 2nd and final year of the 2-year term, results in the Taxpayer's right to receive the
annuity payments having a value equal to 99.99% of the fair market value of the trust fund of
the Trust as finally determined for federal gift tax purposes. The value of the second and
final annuity payable to the Taxpayer is equal to 120% of the value of the prior year's
annuity. The Trust ends on the day before the 2nd anniversary of the Trust Creation Date.
Upon the termination of the Trust, the remaining trust property will be distributed to the
trustees of the Black 2006 Family Trust (the "Family Trust"), to be added to the principal of
the Family Trust and disposed of therewith.
The value of the gift is determined by subtracting the value of the qualified annuity interest
from the value of the property contributed to the Trust. Under Treas. Reg. § 25.2702-2(6)(2),
the value of a qualified annuity interest is determined under Code § 7520.
Accordingly, for the transfer shown as Item I of Schedule A, Part 3 of the Return, there is
shown below (I) the valuation of the initial fair market value of the Trust, (2) the annuity
percentages taken from the Trust Agreement, (3) the annuity term taken from the Trust
Agreement, (4) the § 7520 rate in effect for the month in which the transfers occurred, (5) the
value of the qualified annuity and (6) the resulting gift.
NY1:11$21:433131%1,6901400Ca6504.0001
EFTA01127754
•
On December 21, 2006, the Taxpayer contributed to the Trust a 30.35% limited partnership
interest in Apollo Management VI, LP, a Delaware limited partnership. The Taxpayer
received no consideration from the Trust in return for his contribution. Based on an appraisal
by Empire Valuation Consultants., a copy of which is attached as Exhibit G-4AP, on
December 21, 2006 the gift tax value of the 30.35% limited partnership interest in Apollo
Management VI, LP the Taxpayer transferred to the Trust was $45,600,000.
(I) Initial Fair Market Value of the Trust Fund $45,600,000
(2) Annuity Rate Per Trust Agreement: 49.5683% in year 1; 59.4820% in
year 2
(3) Annuity Term Per Trust Agreement 2 Years
(4) Section 7520 Rate for December 2006 5.8%
(5) Value of Qualified Annuity $45,595,440
(6) Value of Gift $4,560.00
NYB1520413101W/L690ILDOC‘26304.00011 2
EFTA01127755
LEON D. BLACK
Rider 1 to Form 709
United States Gift and Generation Skipping Transfer Tax Return
Calendar Year 2006
Social Securitv No.-
Disclosure Pursuant to Regulation Section 301.6501(c)-1(O(2)
CONTRIBUTION TO JUDAH INVESTMENT 'FROST E (Sch. A. Part 3. Item 1)
The transaction referred to as Item 1 on Schedule A, Part 3 of this Return represents the
contribution by Leon D. Black (the "Taxpayer") to the Judah Investment Trust E (the
"Trust"), created under trust agreement dated December 21, 2006 (the "Trust Creation Date")
between Leon D. Black, as senior, and Leon D. Black and John Hannan, as trustees (the
"Trust Agreement"). The Trust is a grantor-retained annuity trust in which the Taxpayer
retained a Qualified jute.= ac defing.SlitintanaLic e
"Code"). A copy of the Trust Agreement is attached as Exhibit G-5.
Under the terms of the Trust Agreement, an annuity is payable from the Trust to the
Taxpayer (or, if the Taxpayer is not living, to the Taxpayer's estate) on the day before the
first anniversary of the Trust Creation Date, and on the day before the 2nd and final
anniversary of the Trust Creation Date during the Trust's 2-year term. The value of the first
annuity is equal to such percent of the fair market value of the trust fund of the Trust as
finally determined for federal gift tax purposes that, when increased by twenty (20%) percent
in the 2nd and final year of the 2-year term, results in the Taxpayer's right to receive the
annuity payments having a value equal to 99.99% of the fair market value of the trust fund of
the Trust as finally determined for federal gift tax purposes. The value of the second and
final annuity payable to the Taxpayer is equal to 120% of the value of the prior year's
annuity. The Trust ends on the day before the 2nd anniversary of the Trust Creation Date.
Upon the termination of the Trust, the remaining trust property will be distributed to the
trustees of the Black 2006 Family Trust (the "Family Trust"), to be added to the principal of
the Family Trust and disposed of therewith.
The value of the gift is determined by subtracting the value of the qualified annuity interest
from the value of the property contributed to the Trust. Under Treas. Reg. § 25.2702-2(b)(2),
the value of a qualified annuity interest is determined under Code § 7520.
Accordingly, for the transfer shown as Item 1 of Schedule A, Part 3 of the Return, there is
shown below (I) the valuation of the initial fair market value of the Trust, (2) the annuity
percentages taken from the Trust Agreement, (3) the annuity term taken from the Trust
Agreement, (4) the § 7520 rate in effect for the month in which the transfers occurred, (5) the
value of the qualified annuity and (6) the resulting gift.
NY I AI SIC433501W/L69011D0O.26508.0001
EFTA01127756
On December 21, 2006, the Taxpayer contributed to the Trust a 26.8% limited partnership
interest in Apollo Investment Management LP, a Delaware limited partnership. The
Taxpayer received no consideration from the Trust in return for his contribution. Based on
an appraisal by Empire Valuation Consultants., a copy of which is attached as Exhibit G-
5AP, on December 21, 2006 the gift tax value of the 26.8% limited partnership interest in
Apollo Investment Management LP the Taxpayer transferred to the Trust was $227,000,000.
(I) Initial Fair Market Value of the Trust Fund $227,000,000
(2) Annuity Rate Per Trust Agreement: 49.5683% in year 1; 59.4820% in year 2
(3) Annuity Term Per Trust Agreement 2 Years
(4) Section 7520 Rate for December 2006 5.8%
(5) Value of Qualified Annuity $226,977,300
(6) Value of Gift $22,700.00
NYBIS20433VML690111)0026$04.0031 2
EFTA01127757
LEON D. BLACK
Rider 1 to Form 709
United States Gift and Generation Skipping Transfer Tax Return
Calendar Year 2006
Social Security No.
Disclosure Pursuant to Regulation Section 301.6501(c)-I (0(2)
CONTRIBUTION TO JUDAH INVESTMENT TRUST F (Sch. A. Part 3. Item 1)
The transaction referred to as Item 1 on Schedule A, Part 3 of this Return represents the
contribution by Leon D. Black (the "Taxpayer") to the Judah Investment Trust F (the
"Trust"), created under trust agreement dated December 21, 2006 (the "Trust Creation Date")
between Leon D. Black, as senior, and Leon D. Black and John Hannan, as trustees (the
"Trust Agreement"). The Trust is a grantor-retained annuity trust in which the Taxpayer
retain&La Qualified Intereat• as defined in § 2702(b) of the Internal Revenue Code ate
"Code"). A copy of the Trust Agreement is attached as Exhibit G-6.
Under the terms of the Trust Agreement, an annuity is payable from the Trust to the
Taxpayer (or, if the Taxpayer is not living, to the Taxpayer's estate) on the day before the
first anniversary of the Trust Creation Date, and on the day before the 2nd and final
anniversary of the Trust Creation Date during the Trust's 2-year term. The value of the first
annuity is equal to such percent of the fair market value of the trust fund of the Trust as
finally determined for federal gift tax purposes that, when increased by twenty (20%) percent
in the 2nd and final year of the 2-year term, results in the Taxpayer's right to receive the
annuity payments having a value equal to 99.99% of the fair market value of the trust fund of
the Trust as finally determined for federal gift tax purposes. The value of the second and
final annuity payable to the Taxpayer is equal to 120% of the value of the prior year's
annuity. The Trust ends on the day before the 2nd anniversary of the Trust Creation Date.
Upon the termination of the Trust, the remaining trust property will be distributed to the
trustees of the Black 2006 Family Trust (the "Family Trust"), to be added to the principal of
the Family Trust and disposed of therewith.
The value of the gift is determined by subtracting the value of the qualified annuity interest
from the value of the property contributed to the Trust. Under Treas. Reg. § 25.2702-2(b)(2),
the value of a qualified annuity interest is determined under Code § 7520.
Accordingly, for the transfer shown as Item I of Schedule A, Part 3 of the Return, there is
shown below (1) the valuation of the initial fair market value of the Trust, (2) the annuity
percentages taken from the Trust Agreement, (3) the annuity term taken from the Trust
Agreement, (4) the § 7520 rate in effect for the month in which the transfers occurred, (5) the
value of the qualified annuity and (6) the resulting gift.
NY 320433% I W116901 WOO26504.000 I
EFTA01127758
On December 21, 2006, the Taxpayer contributed to the Trust a 26.9% limited partnership
interest in Apollo Value Investment Fund Management LP, a Delaware limited partnership.
The Taxpayer received no consideration from the Trust in return for his contribution. Based
on an appraisal by Empire Valuation Consultants., a copy of which is attached as Exhibit G-
6AP, on December 21, 2006 the gift tax value of the 26.9% limited partnership interest in
Apollo Value Investment Fund Management LP the Taxpayer transferred to the Trust was
$9,600,000.
(I) Initial Fair Market Value of the Trust Fund $9,600,000
(2) Annuity Rate Per Trust Agreement: 49.5683% in year I; 59.4820% in
year 2
(3) Annuity Term Per Trust Agreement 2 Years
(4) Section 7520 Rate for December 2006 5.8%
(5) Value of Qualified Annuity $9,599,040
(6) Value of Gift $960
NY 1:1152043310 IMUS9011.D0026504.04101 2
EFTA01127759
•
LEON D. BLACK
Rider 1 to Form 709
United States Gift and Generation Skinning Transfer Tax Return
Calendar Year 2006
Social Security No.
Disclosure Pursuant to Regulation Section 301.6501(c)-1(f)(2)
CONTRIBUTION TO JUDAH INVESTMENT TRUST G (Sch. A, Part 3, item I)
The transaction referred to as Item I on Schedule A, Part 3 of this Return represents the
contribution by Leon D. Black (the "Taxpayer") to the Judah Investment Trust G (the
"Trust"), created under trust agreement dated December 21, 2006 (the "Trust Creation Date")
between Leon D. Black, as settlor, and Leon D. Black and John Hannan, as trustees (the
"Trust Agreement"). The Trust is a grantor-retained annuity trust in which the Taxpayer
retained-a--Qualified-Interestr ag_defined_in...§2702(b) of the InternaLRevertue_Code (the
"Code"). A copy of the Trust Agreement is attached as Exhibit G-7.
Under the terms of the Trust Agreement, an annuity is payable from the Trust to the
Taxpayer (or, if the Taxpayer is not living, to the Taxpayer's estate) on the day before the
first anniversary of the Trust Creation Date, and on the day before the 2nd and final
anniversary of the Trust Creation Date during the Trust's 2-year term. The value of the first
annuity is equal to such percent of the fair market value of the trust fund of the Trust as
finally determined for federal gift tax purposes that, when increased by twenty (20%) percent
in the 2nd and final year of the 2-year term, results in the Taxpayer's right to receive the
annuity payments having a value equal to 99.99% of the fair market value of the trust fund of
the Trust as finally determined for federal gift tax purposes. The value of the second and
final annuity payable to the Taxpayer is equal to 120% of the value of the prior year's
annuity. The Trust ends on the day before the 2nd anniversary of the Trust Creation Date.
Upon the termination of the Trust, the remaining trust property will be distributed to the
trustees of the Black 2006 Family Trust (the "Family Trust"), to be added to the principal of
the Family Trust and disposed of therewith.
The value of the gift is determined by subtracting the value of the qualified annuity interest
from the value of the property contributed to the Trust. Under Treas. Reg. § 25.2702-2(b)(2),
the value of a qualified annuity interest is determined under Code § 7520.
Accordingly, for the transfer shown as Item 1 of Schedule A, Part 3 of the Return, there is
shown below (1) the valuation of the initial fair market value of the Trust, (2) the annuity
percentages taken from the Trust Agreement, (3) the annuity term taken from the Trust
Agreement, (4) the § 7520 rate in effect for the month in which the transfers occurred, (5) the
value of the qualified annuity and (6) the resulting gift.
NYI 52043TORWL690t!DO026504.0001
EFTA01127760
On December 21, 2006, the Taxpayer contributed to the Trust a 44% limited partnership
interest in Apollo SVF Management LP, a Delaware limited partnership. The Taxpayer
received no consideration from the Trust in return for his contribution. Based on an appraisal
by Empire Valuation Consultants., a copy of which is attached as Exhibit G-7AP, on
December 21, 2006 the gift tax value of the 44% limited partnership interest in Apollo SVF
Management LP the Taxpayer transferred to the Trust was $87,000,000
(1) initial Fair Market Value of the Trust Fund $87,000,000
(2) Annuity Rate Per Trust Agreement: 49.5683% in year 1; 59.4820% in
year 2
(3) Annuity Term Per Trust Agreement 2 Years
(4) Section 7520 Rate for June 2004 5.8%
(5) Value of Qualified Annuity $86,991,300
(6) Value of Gift $8,700.00
NY 1:115.2043101W/L6901tD0026504,C001 2
EFTA01127761
LEON D. BLACK
Rider I to Form 709
United States Gift and Generation Skipping Transfer Tax Return
Calendar Year 2006
Social Security No.
Disclosure Pursuant to Regulation Section 301.6501(c)-1(f)(2)
CONTRIBUTION TO JUDAH INVESTMENT TRUST H (Sch. A, Part 3, Item 11
The transaction referred to as Item 1 on Schedule A, Part 3 of this Return represents the
contribution by Leon D. Black (the "Taxpayer") to the Judah Investment Trust H (the
"Trust"), created under trust agreement dated December 21, 2006 (the "Trust Creation Date")
between Leon D. Black, as settlor, and Leon D. Black and John Hannan, as trustees (the
"Trust Agreement"). The Trust is a grantor-retained annuity trust in which the Taxpayer
retain,' a Quatifieft Isits-rect, as defined in § 2702(b) of the jytterrial Revenue Code (the
"Code"). A copy of the Trust Agreement is attached as Exhibit G-8.
Under the terms of the Trust Agreement, an annuity is payable from the Trust to the
Taxpayer (or, if the Taxpayer is not living, to the Taxpayer's estate) on the day before the
first anniversary of the Trust Creation Date, and on the day before the 2nd and final
anniversary of the Trust Creation Date during the Trust's 2-year term. The value of the first
annuity is equal to such percent of the fair market value of the trust fund of the Trust as
finally determined for federal gift tax purposes that, when increased by twenty (20%) percent
in the 2nd and final year of the 2-year term, results in the Taxpayer's right to receive the
annuity payments having a value equal to 99.99% of the fair market value of the trust fund of
the Trust as finally determined for federal gift tax purposes. The value of the second and
final annuity payable to the Taxpayer is equal to 120% of the value of the prior year's
annuity. The Trust ends on the day before the 2nd anniversary of the Trust Creation Date.
Upon the termination of the Trust, the remaining trust property will be distributed to the
trustees of the Black 2006 Family Trust (the "Family Trust"), to be added to the principal of
the Family Trust and disposed of therewith.
The value of the gift is determined by subtracting the value of the qualified annuity interest
from the value of the property contributed to the Trust. Under Treas. Reg. § 25.2702-2(b)(2),
the value of a qualified annuity interest is determined under Code § 7520.
Accordingly, for the transfer shown as Item 1 of Schedule A, Part 3 of the Return, there is
shown below (1) the valuation of the initial fair market value of the Trust, (2) the annuity
percentages taken from the Trust Agreement, (3) the annuity term taken from the Trust
Agreement, (4) the § 7520 rate in effect for the month in which the transfers occurred, (5) the
value of the qualified annuity and (6) the resulting gift.
NY I ft1520433'O11M1.690ILDOCU6504.0001
EFTA01127762
On December 21, 2006, the Taxpayer contributed to the Trust a 44% limited partnership
interest in Apollo Asia Management LP, a Delaware limited partnership. The Taxpayer
received no consideration from the Trust in return for his contribution. Based on an appraisal
by Empire Valuation Consultants., a copy of which is attached as Exhibit G-SAP, on
December 21, 2006 the gift tax value of the 44% limited partnership interest in Apollo Asia
Management LP the Taxpayer transferred to the Trust was $20,800,000.
(1) Initial Fair Market Value of the Trust Fund $20,800,000
(2) Annuity Rate Per Trust Agreement: 49.5683% in year 1; 59.4820% in
year 2
(3) Annuity Term Per Trust Agreement 2 Years
(4) Section 7520 Rate for December 2006 5.8%
(5) Value of Qualified Annuity $20,797,920
(6) Value of Gift $2,080.00
NY1:11320431101\WL69011D0O26504.0001 2
EFTA01127763
LEON D. BLACK
Rider I to Form 709
United States Gift and Generation Skipping Transfer Tax Return
Calendar Year 2006
Social Security No.
Disclosure Pursuant to Regulation Section 301.6501(c)-1(f)(2)
CONTRIBUTION TO JUDAFI INVESTMENT TRUST I (Sch. A. Part 3, Item 1)
The transaction referred to as Item 1 on Schedule A, Part 3 of this Return represents the
contribution by Leon D. Black (the "Taxpayer") to the Judah Investment Trust I (the
"Trust"), created under trust agreement dated December 21, 2006 (the "Trust Creation Date")
between Leon D. Black, as senior, and Leon D. Black and John Hannan, as trustees (the
"Trust Agreement"). The Trust is a grantor-retained annuity trust in which the Taxpayer
retainecLa_Qiialifiert inferno ac defined in § 77.02(b)_...oftheinte.maLReventte Code (the
"Code"). A copy of the Trust Agreement is attached as Exhibit G-9.
Under the terms of the Trust Agreement, an annuity is payable from the Trust to the
Taxpayer (or, if the Taxpayer is not living, to the Taxpayer's estate) on the day before the
first anniversary of the Trust Creation Date, and on the day before the 2nd and final
anniversary of the Trust Creation Date during the Trust's 2-year term. The value of the first
annuity is equal to such percent of the fair market value of the trust fund of the Trust as
finally determined for federal gift tax purposes that, when increased by twenty (20%) percent
in the 2nd and final year of the 2-year term, results in the Taxpayer's right to receive the
annuity payments having a value equal to 99.99% of the fair market value of the trust fund of
the Trust as finally determined for federal gift tax purposes. The value of the second and
final annuity payable to the Taxpayer is equal to 120% of the value of the prior year's
annuity. The Trust ends on the day before the 2nd anniversary of the Trust Creation Date.
Upon the termination of the Trust, the remaining trust property will be distributed to the
trustees of the Black 2006 Family Trust (the "Family Trust"), to be added to the principal of
the Family Trust and disposed of therewith.
The value of the gift is determined by subtracting the value of the qualified annuity interest
from the value of the property contributed to the Trust. Under Treas. Reg. § 25.2702-2(6)(2),
the value of a qualified annuity interest is determined under Code § 7520.
Accordingly, for the transfer shown as Item 1 of Schedule A, Part 3 of the Return, there is
shown below (1) the valuation of the initial fair market value of the Trust, (2) the annuity
percentages taken from the Trust Agreement, (3) the annuity term taken from the Trust
Agreement, (4) the § 7520 rate in effect for the month in which the transfers occurred, (5) the
value of the qualified annuity and (6) the resulting gift.
NY1:1020433
ℹ️ Document Details
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315670dce9f7d61c084decf2c86d285338b8881e687db6b739da7d18870c2959
Bates Number
EFTA01127743
Dataset
DataSet-9
Document Type
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Pages
27
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