EFTA02557035.pdf

From: Eileen Alexanderson Sent: Thursday, July 5, 2012 7:02 PM To: 'Jeffrey Subject: RE: follow up See Article II on pgs 1-2 of the 2006 Trust Doc attached to my last email f=r language related to distribution of 'trust accounting income' from opera=ing profits of 'relevant companies' which you will see detailed in II(A)3.=The 'relevant companies' are the Apollo entities Leon had ownership intere=ts in that he contributed into the GRATs that poured into the 2006 Trust. =here isn't specific language surrounding the principal. The trusts owns th= interests in Black Family Partners and the monetization of the value of t=e BRH interests would not constitute 'trust accounting income' from 'opera=ing profits' and would therefore remain in the trust. I will next forward a summary entitled 'History/Structure' that I wrote for=myself early on as I was trying to come up to speed on what had been put i= place. I believe I left you a hard copy which was behind the org chart of=Black Family Partners. There is a section on the first page with comments =n FLPs-I was in an education mode and, with hindsight, did not fully under=tand the control issues but I think otherwise this will help you understan= where we came from. Importantly, you will see there were 2 sets of GRATs. The termination of GR=Ts A-K went as planned. But the second set, GRATs L-O lacked sufficient ca=h to make the final annuity payment to Leon so we did an inkind transfer o= the Black Family Partners these GRATs owned to Leon and then he contribut=d these into a new GRAT, the Judah 2009 Trust. We made that a 4 year GRAT =nstead of 2 years like the original ones we did because I felt we would no= have generated enough cash in 2 years to make the annuity payments to Leo=. Original Message From: Jeffrey (mailto:[email protected] Sent: Thursday, July 05, 2012 1:46 PM To: Eileen Alexanderson Subject: Re: follow up Send me grat docs that separate income from capital appreciation Sorry for all the typos .Sent from my iPhone On Jul 5, 2012, at 12:09 PM, Eileen Alexanderson rote: > Jeffrey, thinking back through dialogs with Carlyn & Elyse and looking at=some of my old notes from those dialogs that relate to our conversation th=s morning I offer the following: > Regarding the issue of why turning off the income right now works is that=it would be the independent trustees turning off the income right, not Leo=, and that the 2006 Trust was drafted purposely in anticipation of this. l=believe this relates to the language on page 30 in the attached. > Also, Ada (from US Trust) at one point had suggested to Carlyn that we co=sider having the trustees turn of the income right in the 2006 Trust and t=en decant the assets from the 2006 Trust into a new trust before proceedin= with the Art Partnership to insure a cleaner transaction. > Also, on the subject of the 2006 Trust and other trust paying their own t=xes-important implication for Black Family Partners would be that we no lo=ger have a single taxpayer. EFTA_R1_01715895 EFTA02557035 > Best, > Eileen > Original Message > From: NY_730_11_XRX_COPYROOM > [mailto:[email protected]]=20 > Sent: Thursday, July OS, 2012 12:06 PM > To: Eileen Alexanderson > Subject: Scan from a Xerox Color > Please open the attached document. It was scanned and sent to you using = Xerox Color. > Number of Images: 60 > Attachment File Type: PDF > Device Name: NY_730_11_XRX_COPYROOM > Device Location: > For more information on Xerox products and solutions, please visit > http:/=www.xerox.com/ > This email and any files transmitted with it are confidential and > intended solely for the person or entity to whom they are addressed > and may contain confidential and/or privileged material. Any review, > retransmission, dissemination or other use of, or taking of any action > in reliance upon this information by persons or entities other than > the intended recipient is prohibited. If you have received this email > in error please contact the sender and delete the material from any > computer. > Apollo Global Management, LLC > <img-705120530-0001.pdf> This email and any files transmitted with it are confidential and intended solely for the person or entity to whom they are addressed and may contain confidential and/or privileged =material. Any review, retransmission, dissemination or =other use of, or taking of any action in reliance upon this information by persons or entities other than the intended =recipient is prohibited. If you have received this email in =error please contact the sender and delete the material from =any computer. 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