EFTA01135798.pdf

From: Eileen Alexanderson To: 'Jeffrey Epstein' <[email protected]> Subject: FW: Section 734 Date: Mon, 13 May 2013 19:02:02 +0000 Attachments: From: Fenn, Patrick [mailto: Sent: Saturday, April 06, 2013 4:29 PM To: Eileen Alexanderson; ; 'Thomas Turrin' Subject: FW: Section 734 Hi. The attachment shows that, even under the most favorable conditions in the deferral context (20 year deferral of tax on Tufts gain but full TRA benefits beginning in 21st year at a 7.5% discount rate), the value of TRA benefit is $16.5 million for Leon. Other than by altering the discount rate and the tax rates, I don't think the TRA benefit in the deferral (guarantee) scenario will get much better. I will leave to you to determine whether that might be enough to overcome the non-tax aspects of the guarantee. Let me know if you want to discuss. IRS Circular 230 Notice Requirement: This communication is not given in the form of a covered opinion, within the meaning of Circular 230 issued by the United States Secretary of the Treasury. Thus, we are required to inform you that you cannot rely upon any tax advice contained in this communication for the purpose of avoiding United States federal tax penalties. In addition, any tax advice contained in this communication may not be used to promote, market or recommend a transaction to another party. The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. 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 EFTA01135798