Taxpayers: Leon Black and Debra Black ("Taxpayers") SSNs: Tax Form: 1040X Tax Year: 2012 Program for Voluntary Disclosure of Delinquent International Information Returns Statement of Reasonable Cause Timely 8938 Taxpayers, husband and wife, are hereby voluntarily filing the attached Form 1040X (the "Amended Return") for the sole purpose of filing Forms 5471, 8865, 8858 and 8938 (the "International Information Returns") for 2012, 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 Retran-w-11.,any delinquent filing of International Information Returns and have a long history of being fully compliant taxpayers. The Taxpayers are not under civil examination emir 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 2012 (the "Original Return") was due to reasonable cause and not willful neglect. The addition, the only change reflected in the Form 1040X being 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 2012, 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 Matter & Co. LLP ("REM-Co"). Background The Taxpayers own interests in a wide variety of entities related-teaffiliated with Apollo Global Management, LLC ("Apollo"), the publicly traded alternative asset manager, through their interest in BRH Holdings, L.P. ( I ("BRH" or the "Partnership"). Sinee the-ineeptien-el-BRHr empleyees-efapelle-haye-assisted-veithIn addition to their responsibil