From: Thomas Turrin Sent: Thursday, May 1, 2014 124 PM To: Richard Joslin Cc: Abel Goce; Jeffrey Epstein; tax Subject: Re: GSCO IMY accounts Yes...agreed Sent from my Verizon Wireless 4G LTE =ROID Richard Joslin wrote: Please dont forget to take out $250K of interest income (GSCO) in the =012 amended return On Mar 28, 2014, at 4:04 PM, "Richard Joslin" wrote: See screenshot belo= that shows BRH ownership of AP Professionals which owns Apollo Operating =roup. BRH Holdings LP has a 98- prefix (a foreign partnership). = Foreign partnerships are assigned EIN's with a 98 prefix http://www.irs.gov/irm/part21/irm_21.007.013r.html <http://www.irs.gov/irm/part21/irm_21.007.013r=html> . AP Pro=essional Holdings, L.P., an exempted limited partnership formed under the =aws of the Cayman Islands, http://www.sec.gov/Archives/edgar/data/1411494/000119312513204748/d532543de=101.htm chttp://www.sec.gov/Archivegedgar/data/1411494/00011931251320474./d532543dex101.htm> The foreign partnerships are non-withholding partn=rship for purposes of Sec 1441 (they have not elected with the IRS to be t=eated as a withholding foreign partnership for US tax purposes. AP Professionals ha= an account at GSCO. Since AP professionals is a non-withholding foreign p=rtnership and since the owner of AP Professioanls (BRH) is also a non-with=olding partnership, GSCO is reporting income directly to the US owners of BRH. This is accomplished by AP =rofessional issuing a W-8 IMY to GSCO and giving GSCO the W-8-IMY of BRH w=ich reflects the US owners of BRH. GSCO issues 1099's directly to =5 owner. We know that BRH is owned by BFP LP (not LDB). The BRH K-1 was picked up by BFP but this 1099 was reported =irectly on LDB's 1040 (should have been BFP pro forma K1 (if not reporte= by BRH)). The AP Professional LP income was picked up by BRH Holdin=s. I confirmed with Apollo. Summary: GSCO=1099s issued under LEON BLACK IMY-AP PROFESSIONAL HOLDINGS LP were r=ported twice in 2012 — o