EFTA02366564.pdf

From: Thomas Turrin Sent: Sunday, February 12, 2017 12:58 PM To: jeffrey E. Subject: RE: Re: yes...will call in about 10 min. From: jeffrey E. [mailto:[email protected] Sent: Sunday, February 12, 2017 7:56 AM To: Thomas Turrin Subject: Re: can you call me for a quick quesiton On Sun, Feb 12, 2017 at 7:40 AM, Thomas Turrin wrote: I will review Jeffrey's comments and respond later today. Sent from my iPhone > wrote: > I agree barry. Jeffrey- > 1. With this note im going to forward your sentence for the RC letter > to the PW people and suggest they reach out to you (or vice versa) with expect to your suggested placement. I assume you're just suggesting an amplification of the already existing sentence but not 100% certain. (Brian or brad, pls confirm receipt of this email.) 2. Is it clear where on the cover sheet of the 1040x you wld like your suggested statement. Pls let me/tom know. > 3. Again, by copy of this note I am forwarding your comments to torn for incorporation or review (torn, cld u pls confirm receipt of this note and interact with jeffrey as necessary so we can finalize). > Thx, brad > Sent from my Verizon Wireless BlackBerry Original Message > From: "Barry J. Cohen > Date: Sat, 11 Feb 2017 19:55:51 > To: jeffrey [email protected] <mailto:[email protected]»; > Brad wechster<BAIIIIIMINIMINIMMIIMPIIMMOIMIlla; Leon > Black< • > Subject: Re: EFTA_R1_01363646 EFTA02366564 > Seems fine but I have no strong view. > Sent from my iPhone > On Feb 11, 2017, at 2:27 PM, jeffrey E. <[email protected] <mailto:[email protected]> <mailto:[email protected] <mailto:[email protected]> » wrote: > 1. modifications. = I d prefer the letter to state. In order to comply with the the proscribed filing procedures the taxpayers are certifying that these foreign entities are not now and have never engaged in tax evasion. > 2 .on the front of the 1040 x. the statement to the effect that this return is being filed soley as required to provide the delinquent information returns. There is no tax owed. please see attached statement of reasonable cause. 3 many of the 5471. boxes should say " date of incorporation " somehow the box only says date of ? 4. we should review the boxes that say date of last filing of the shareholders 1040. . > -- > please note > The information contained in this communication is confidential, may > be attorney-client privileged, may constitute inside information, and > is intended only for the use of the addressee. It is the property of > JEE Unauthorized use, disclosure or copying of this communication or > any part thereof is strictly prohibited and may be unlawful. If you > have received this communication in error, please notify us > immediately by return e-mail or by e-mail to [email protected] > <mailto:[email protected]> <mailto:[email protected] > <mailto:[email protected]», and destroy this communication and > all copies thereof, including all attachments. copyright -all rights > reserved 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 please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 2 EFTA_R1_01363647 EFTA02366565