Taxpayers: Leon Black and Debra Black ("Taxpayers") SSNs: Tax Form: 1040X Tax Year: 2014 Program for Voluntary Disclosure of Delinquent International Information Returns Statement of Reasonable Cause for--Failure4o--Timely-lzile-FOFMS-54743-886-5r 88-58-and 8938 Taxpayers, husband and wife, are hereby voluntarily filing the attached Form 1040X (the "Amended Return"), as well as a reasonable cause statement under Treas. Reg. § 1.6038- 2T(j)(3), for the sole purpose of filing Forms 5471, 8865, 8858 and 8938 (the Forms, together with the aforementioned statement, the "International Information Returns") for 2014, 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 • International Information Returns and have a long history of being fully compliant taxpayers. The Taxpayers are not under civil examination erttox criminal investigation by the IRS. This submission, pursuant to Treas. Reg. §§ I.6038-2(k)(3) and I.6038-3(k)(4), explains why the Taxpayers' failure to file the International Information Returns with the original Form 1040 for 2014 (the "Original Return") was due to reasonable cause and not willful neglect. Theja addition, the only change reflected in the Form 1040X b ' g filed today is the inclusion of the International Information Returns, and there is no change in either taxable income reported by the Taxpayers, or in the tax liability owed by the Taxpayers, for 2014, which was timely paid. The Original Return, the Amended Return and the accompanying International Information Returns were all 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 relatecHeaffiliated with Apollo Global Management, LLC ("Apollo"), the publicly traded alternative asset manager, through their interest in BRH Ho