Re: Planning

Jeffrey — Leon asked me to ask you. Debra is going to =hicago May 30th — back and forth the same day. Here is the respons= from Jet

Hi Melanie,

For May 30th with the 12pm departure out of Teterboro and llpm=departure out of Chicago the duty day is at 15hrs18min. For 135 trips crew=cannot exceed 14hr duty day. If you wish to operate this flight as 135 we =ust do a crew swap in Chicago. If we were to operate this fight as 91with a Chief Pilot approval we could extended =he duty day to 16hrs. Please let me know how you wish to proceed.

Can we switch to 91 – Here is what they said about the diffe=ence:

When operation 91 the owner has operation control and we have = little bit of flexibility with extending the duty day as long the chief p=lot approves it.

When operation 135 its consider business and the rules are a lot stricter. We are not able to extend the duty day. Two pilots can only be=on duty up to 14hrs and no more than 10hrs of flight time.

Thank you!

Melanie Spinella | Apollo Management
20 W 57th St New York New York 10019

Executive Assistant to Leon D. Black
This email and any files transmitted with it are confidential =nd intended solely for the person or entity to whom they are addressed and=may contain confidential and/or privileged material. Any review, retransmi=sion, dissemination or other use of, or taking of any action in reliance upon this information by persons or entit=es other than the intended recipient is prohibited. If you have received t=is email in error please contact the sender and delete the material from a=y computer. Apollo Global Management, LLC

ex

We are factoring this into our structure recommendations. = Lots of constraints. Apollo doesn't want to be an owner or an opera=or. Makes 91 operations for Apollo tricky.

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Apollo?

what is an apollo flight . ? when will we hav= the proforma ? the gift tax paid but still fraud=nbsp; fable is just that . cant be found because i= doesnt exist. you are getting childish advice and data. = ? sorry. I was very clear with leon that you need a senior tax advisor . person. Joe V is no= it. you have bookkeepers , accountants an= enad y compliance. you going around to others to see how the= work is in my opinion the height of silliness. &n=sp; I consider you tthe best thing that happened to elysium . and have been quite vocal about it. = hire the best people . they cost money. This=biz is leons most important asset that he will leave to his kids. . =t will be responsbile for a whole host of family , estate. operating issue=. .

i have not gottten involved in the documentation , of what is there&nb=p; . and its acccesibility. i would guess pretty g=od now. For ex , my disccusions with other=clients are a give and take , of laws mecahnisms. tactic= strategys.. audit prep. . case law.. a joint composition of high level pla=ning . reporting. analyisis, alternatives. =nbsp; hearing about an article that your guy might have read in his =entitst office. that turns out to be bogus. is emblematic of the off=ce. I am confient that you will grow into the job, . re clats = only asked if any of your so called advisors have actually done one=so they understand its true and pracitcal pitfalls. = your response that the art will be sold quickly. and t=at there is a chapter in lerners book about it , the same book that leon relied on to his detrim=nt before. ( 1031 ) . was suprising, . if the art =s to be sold quickly ( not sure leon would sign on. )&nb=p; , DO it before he dies. not after. art delays the cl=sing of the estate. leon is the "BEST seller. , know the=market etc. gains can be dealt with .

I real tax advisor should demand at least lm per year.&nbs=; up to 3 . all the big firms have a mandatory retireme=t at age 60. high level people all on the street. = my friends biz that only grosses 60 m just hired one for a ml=lion. guys that have hand filled out PERSONAL tax returns TRUST returns . = planned strategies years in advance. . Audit experience=nbsp; preferable large case. . some tax court experience=nbsp; helpful. . filled out estate tax docs ( VERY=IMPORTANT )

Apollo flight is one that qualifies for Apollo reimbursement and Apoll= pays for.

Pro forma depends on when Apollo gives us data. Hopefully very soon.

Gift tax case wasn't "advice". Just a blurb Joe =ead in a publication. He might well have got it wrong.

It was just somethi=g he thought he remembered and mentioned in passing. He was making t=e point that it might be a bad idea for a tax return to have info that is factually wrong even if the tax is right. Whether the case ex=sts or not, that advice hardly seems crazy.

Joe V is the best person we saw and is doing a great job. We have hire= top lawyers and accountants. Always glad to see better people but we are =ot finding them. And very hard to find jacks of all trades. We tend =o see narrow expertise.

S&C reviewed our estate planning and basically said everything we =re doing is fine. EY reviewed our income tax planning and has been helpful= but has not had great suggestions for changing anything.

If you see specific things we should be doing differently let us know =hat they are. If you know of people who will have greater insight than the=ones we are using, we are eager to talk to them.

I too wish Leon would sell more art. We may have losses to parti=lly offset art gains. To the extent we do not, as you have pointed out, ge=ting a step up on death may be preferable for the pieces with gain. In any=event, we don't know if Leon is willing to sell. So we cannot plan around that. My goal is to be able to tell him =quot;lf you sell certain art you will achieve the following benefits."= Not quite there yet.

On the CLATs, I hear you that no one has experience with art. But as y=u have pointed out, Leon's situation is unique. Unless we hear specific re=sons why it doesn't work it is hard to ignore the unanimous chorus of opin=ons that it is a sound planning tool.

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re planning tool' sorry, no =ne has fully examined the issues. saying clats in low in=erest environments make sense is an of course. it is.&nb=p; but ..,. anyway im aval to talk tues

We think we have examined it extremely carefully. Ada, Paul Weiss, S&a=p;C. We are open to the possibility that we are missing something, but no =ne has been able to say what that might be.

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