EFTA02382902.pdf

From: Richard Joslin Sent: Thursday, May 1, 2014 2:46 PM To: Thomas Turrin; Abel Goce Cc: tax; Jeffrey E. Subject: RE: GSCO IMY accounts Attachments: Untitled attachment 00238.eml (1.31 KB) You must not have opened the file I sent on April 21. Cost and dates are shown - see col B for dates — there is summary tab and two detail tabs; cost and proceeds in col G and H on each detail tab From: Thomas Turrin [mailto Sent: Thursday, May 01, 2014 9:40 AM To: Jeffrey E. Cc: Richard Joslin; Abel Goce; tax Subject: Re: GSCO IMY accounts I will be in on Monday morning. I will review the draft first thing and post it to the portal for Rich. I will be available to review with Rich on Monday. In order to finalize the amended return, we will need the dates of acquisition and cost details of the works sold...and dates of sale and proceeds of sale. For the draft, we are using the net gain estimates. Sent from my Verizon Wireless 4G LTE DROID "Jeffrey E." <[email protected] <mailto:[email protected]> wrote: when will i have the draffmr, On Thu, May 1, 2014 at 3:24 PM, Thomas Turrin > wrote: EFTA_R1_01399102 EFTA02382902  Yes...agreed Sent from my Verizon Wireless 4G LTE DROID Richard loslin < > wrote: Please dont forget to take out $250K of interest income (GSCO) in the 2012 amended return on Mar 28, 2014, at 4:04 PM, "Richard Joslin" > wrote: See screenshot below that shows BRH ownership of AP Professionals which owns Apollo Operating Group. BRH Holdings LP has a 98- prefix (a foreign partnership). Foreign partnerships are assigned EIN's with a 98 prefix http://www.irs.gov/irm/part21/irm_21-007-013r.html <http://www.irs.gov/irm/part21/irm_21-007-013r.html> . AP Professional Holdings, L.P., an exempted limited partnership formed under the laws of the Cayman Islands, http://www.sec.gov/Archives/edgar/data/1411494/000119312513204748/d532543dex101.htm <http://www.sec.gov/Archives/edgar/data/1411494/000119312513204748/d532543dex101.htm> The foreign partnerships are non-withholding partnership for purposes of Sec 1441 (they have not elected with the IRS to be treated as a withholding foreign partnership for US tax purposes. AP Professionals has an account at GSCO. Since AP professionals is a non-withholding foreign partnership and since the owner of AP Professioanls (BRH) is also a non-withholding partnership, GSCO is reporting income directly to the US owners of BRH. This is accomplished by AP Professional issuing a W-8 IMY to GSCO and giving GSCO the W-8-IMY of BRH which reflects the US owners of BRH. GSCO issues 1099's directly to US owner. We know that BRH is owned by BFP LP (not LOB). The BRH K-1 was picked up by BFP but this 1099 was reported directly on LDB's 1040 (should have been BFP pro forma K1 (if not reported by BRH)). The AP Professional LP income was picked up by BRH Holdings. I confirmed with Apollo. Summary: GSCO 1099s issued under LEON BLACK IMY-AP PROFESSIONAL HOLDINGS LP were reported twice in 2012 — once on LDB 1040 and once on K-1 for BFP LP. Taxable income overstated by — $250K. Accounts: 681-57975-1 2 EFTA_R1_01399103 EFTA02382903  681.583332 The pages upload to portal of the 1099 for 681-58001-5 have been left out — I can't see for certain but likely also IMY-AP PROFESSIONAL HOLDINGS LP Oddly I don't see these GSCO accounts for AP Professional are reported on 1040 for 2011 but they are reported in 2010 (in addition to other GSCO accounts) and 2009. 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