EFTA02400399.pdf
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From:
Marc Rowan
Sent:
Thursday, March 3, 2016 10:26 PM
To:
Jeffrey Epstein
Subject:
Fwd: TRA Valuation Process
Fyi
Sent from my iPhone
Begin forwarded message:
From: Chris Weidler ‹
»
Date: March 4, 2016 at 12:19:12 AM GMT+2
To: Marc Rowan
Subject: RE: TRA Valuation Process
Marc
For purposes of establishing the balance sheet asset the DTA/TRA are undisc=unted.
Each period we re-assess our ability to realize the asset over the allotted=time frame. If we have any concerns we
would then establish a valuation =llowance
We also review the tax rate each period and if that changes for any reason =new York state rate change, etc) we apply
that change and adjust the DTA/T=A. This we have done in 13 and 14 as there were rate changes.
chris
From: Marc Rowan
Sent: Thursday, March 03, 2016 5:05 PM
To: Chris Weidler
Subject: Re: TRA Valuation Process
This tells me what I already know. What rate do we discount future cash flo=s/TRA pmts at for purposes of establishing
the balance sheet asset?
Sent from my iPad
On Mar 4, 2016, at 12:02 AM, Chris Weidler <
> wrote:
Marc,
Please see below for how the deferred tax asset ('0TA') and tax receiva=le agreement (TRA') is calculated as well as the
key inputs into the =omputation. I tried to simplify as much as possible but obviously a compl=x calculation. Please let
me know if this is sufficient or if you need mo=e. We have example detailed calculations if you would find that useful.
EFTA_R1_01435799
EFTA02400399
Each exchange related to the TRA is valued using a multi -step process desc=ibed below
The TRA is valued as 85% of DTA that is created as a result of an AOG excha=ge. The DTA is calculated as:
cimage002.png>
The tax rate is the combined federal and state rates. Currently 38.83% for=AGM
The DTA is then amortized over 15 years. 85% of the tax benefit derived fr=m the amortization for any given year is paid
out to the individuals that =xchanged.
Each actual TRA payment then creates additional DTA/TRA calculated as
TRA payment X the current tax rate
Notes:
*The % of the business allocated to taxable entities is calculated as
the present value of the future cash flows attributable to taxable entities=as a % of the present value of the total cash
flows of the business. This=% is -75% as of 12/31/2015.
The key inputs used to determine the present value of the cash flows attrib=table to AMH and the total business are
o Management Fees and Carried Interest cash flows sourced from the most r=cently approved 5-year Budget Plan
o Management Fee Cash Flows are discounted by - 8-14% and Carried Interest=Cash Flows are discounted by 20%
o For perpetual funds and unidentified future funds a Long-Term Growth ra=e of 3% is applied with a discount rate of
10-20% to determine the Termina= Value of these entities.
The results of the fair values of the Management Fees and Carried Interest =ash flows are mapped to the appropriate
parts of the business to determine=the final allocation of value that is attributable to taxable entities.
Regards
Chris
This email and any files transmitted with it are confidential and intended =olely for the person or entity to whom they
are addressed and may contain =onfidential and/or privileged material. Any review, retransmission, dissem=nation or
other use of, or taking of any action in reliance upon this info=mation by persons or entities other than the intended
recipient is prohibi=ed. If you have received this email in error please contact the sender and=delete the material from
any computer. Apollo Global Management, LLC <?xml version=.0" encoding=TF-8"?> <!DOCTYPE plist PUBLIC "-
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| Filename | EFTA02400399.pdf |
| File Size | 194.0 KB |
| OCR Confidence | 85.0% |
| Has Readable Text | Yes |
| Text Length | 4,150 characters |
| Indexed | 2026-02-12T16:18:00.203812 |