EFTA00624765.pdf

APOLLO Tax Receivable Agreement (TRA) Payment Workbook Tax Year 2012 Partner Version 4'8'2013 EFTA00624765 APOLLO Page TRA Related Payment 3 Net Tax Benefit Allocated 4 Tax Benefit Schedule - Payment to TRA Holders 5 Tax Benefit Schedule - Realized Tax Benefit - APO Corp 6 Interest Amount Calculation 2 of 6 Index EFTA00624766 TRA Payment For the Year Ended 12.31.2012 TRA payment $ 30,402,688 Gross-up distribution L 55,214,569 2012 • ayment AP Professionals TRA Holder TRA Ownership % Amount Ownership ross-up Distribution Total Leon Black 41.0768% 12.488.460 38.6363% 21,332,877 33,821,337 3 of 6 EFTA00624767 Apollo Global Management, LLC Tax Benefit Payments - Article III December 31, 2012 TRA Reference (Article III) Description Amount Notes 3.01(b)(1).(3) APO Corp. 2012 Tax Year Realized Tax Benefit (Detriment) 35,728,291 3.01(b)(2).(4) Excess Realized Tax Benefit (Detriment) 3.01(b) Adjusted Realized Tax Benefit 35,728,291 3.01(b) 85% Per TRA 85% 3.01(b) Tax Benefit Payment (includes Imputed Interest under IRC Section 483) 30 369 047 !RC Section 483 Imputed Interest (installment sale rules) 7,611,137 Section 483 Interest Rate (5.15%) • LT AFR Present Value of Tax Benefit Payment from April 12, 2013 to July 14, 2007 = Total Sales Proceeds 22,757,911 3.01(b) Interest Amount Per TRA (Through April 12, 2013) 33,641 3.01(0 Total Net Tax Benefit - i.e., Tax Benefit Payment related to 2012 Tax Return 30 402 688 Notes: ( 1) To calculate the amount of imputed installment sale interest that is taxable on the tax retum the Applicable Federal Rate (AFR) that applies to the term of the installment sale on the date of the sale (July 13, 2007) was used. The AFR was 5.15%. (2) The present value of the Tax Benefit Payment is calculated using the following formula: Amount of Future Payment ( 3) 1 + (# of days July 15, 2007 to April 12, 2013)/365 x Annual Interest Rate) Amount of Future Payment Annual Interest Rate (Long term AFR for July 2007) # of Days (July 15, 2012 through April 12, 2013) Interest is calculated from the due date of the 2012 Tax Retum (without extensions). Please see the attached calculation. 4 ot 6 30,369,047 5.15% 2,097 EFTA00624768 Apollo Global Management, LLC Tax Benefit Schedule - Article II Section 2.03 December 31, 2012 Descriptions A Non-Stepped Up Tax Liability B Actual Liability C.A-B Realized Tax Benefit Partnership Distributive Share Income/(Loss) $101,624,156 $101,624,156 Standalone APO Corp Income ($502) (5502) Section 197 Amortization (69,853,985) Sec 483 Imputed Interest (1,231,680) Interest Expense on Late Payment (8,038) Net Operating Loss Carryforward (46,500,703) Charitable Contribution Addback - 91,607 Special deductions (48,512) (48,512) State & Local Taxes (4,225,697) (26,535) Taxable Income 597.349,445 ($15,954,191) Federal Income Tax 34,072,308 FTC Credit (2,543,179) AMT Tax Liability Federal Tax Liability (Greater of Regular or AMT) 31,529,129 2012 State Income Tax (NY, NYC, CA) 4 225 697 26,535 35,754,826 26,535 Total 2012 Current Tax Liability 35 754 826 S A. With respect to any Taxable Year, the liability for Taxes of APO Corp., including with respect, directly or Indirectly, to the income and gains allocable to APO Corp. from any Partnership in which APO Corp. owns 'an interest using the same methods, elections,conventions and similar practices used on APO Corp.'s Return, but calculated using the Non—Stepped Up Tax Basis instead of the tax basis of the Original Assets and excluding any deduction attributable to the Imputed Interest. 5o46 EFTA00624769 Apollo Global Management, LLC TRA Late Payment Interest Calculation December 31 2012 Tax Benefit Payment $ 30,369,047.46 Interest Amount' $ 33,640.72 Total Payment 30 002 688 LIBOR (assumed Rate for the Cumulative to be 6 month Plus 100 Interest Monthly Tax Benefit Period Date for LIBOR' rate) Basis Points Amount Interest Payment Amount March 15 to March 31, 2013 28-Mar-13 0.4449% 1.00% 1.44% 19,235 0 30,388,283 April 1 to April 12, 2013 8-Apr-13 0.4419% 1.00% 1.44% 14,406 C 30,402,688 Reflects TRA payment occuring on April 12, 2013. 2 Means for each month (or portion thereof) during any period, an interest rate per annum equal to the rate per annum reported, on the date two days prior to the first day of such month, on the Telerate Page 3750 (or if such screen shall cease to be publicly available, as reported on Reuters Screen page "MO" or by any other publicly available source of such market rate) for London interbank offered rates for U.S. dollar deposits for such month (or portion thereof). 6ot EFTA00624770