Taxpayers: Leon Black and Debra Black (-Taxpayers") SSNs: Tax Form: 1040X Tax Year: 2010 Statement of Reasonable Cause for Failure to Timely File Forms 5471, 8865 and 8858 Taxpayers, husband and wife, are voluntarily filing the attached Form 1040X (the "Amended Return") for the sole purpose of filing Forms 5471, 8865 and 8858 (the "International Information Returns") for 2010, under the Internal Revenue Service's (the "IRS") 2014 Delinquent International Information Return Submission Procedures. The Taxpayers have not been contacted by the IRS regarding the Amended Return or the International Information Returns and have a long history of being fully compliant taxpayers. The Taxpayers are not under civil examination or criminal investigation by the IRS. This submission, pursuant to Treas. Reg. §§ 1.6038-2(k)(3) and 1.6038-3(k)(4), explains why the Taxpayers' failure to file the International Information Returns with the original Form 1040 for 2010 (the "Original Return") was due to reasonable cause and not willful neglect. The only change reflected in the Form 1040X filed today is the inclusion of the International Information Returns, and there is no change in taxable income reported by the Taxpayers, or in the tax liability owed by the Taxpayers, for 2010, which was timely paid. The Original Return, the Amended Return and the accompanying International Information Returns were prepared by the Taxpayers' professional accountants at Raich Ende Malter & Co. LLP ("REM-Co"). Background The Taxpayers own interests in a wide variety of entities related to Apollo Global Management, LLC ("Apollo"), the publicly traded alternative asset manager, through their interest in BRH Holdings, L.P. (EIN: 98-0541994) ("BRH" or the "Partnership"). Since the inception of BRH, employees of Apollo have assisted with the preparation of the tax returns of BRH as well as all the other controlled foreign partnerships, controlled foreign corporations and foreign di