EFTA00663505.pdf

From: Thomas Turrin To: jeffrey E. <[email protected]> CC: Richard Abel Goce < , tax Subject: Re: GSCO IMY accounts Date: Thu, 01 May 2014 13:39:33 +0000 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]> wrote: when will i have the draft????? On Thu, May 1, 2014 at 3:24 PM, Thomas Turrin < > wrote: Yes...agreed Sent from my Verizon Wireless 4G LTE DROID Richard Joslin aa 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. AP Professional Holdings, L.P., an exempted limited partnership formed under the laws of the Cayman Islands, httplAvww.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. EFTA00663505  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 LDB). 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: The pages upload to portal of the 1099 foi also IMY-AP PROFESSIONAL HOLDI iimi ave been left out — I can't see for certain but likely 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. Very small amounts in those years. <image001.png> CONFIDENTIALITY STATEMENT: The information contained in this electronic communication. including any and all attachments and enclosures. may be privileged and is strictly confidential, intended solely for the use of the person(s) identified above to receive this communication. If you are not the person(s) identified above to receive this communication, you are hereby notified that you may not disclose print copy, disseminate. or otherwise use the information contained herein. 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