Epstein File EFTA00872266: Apollo Management, Forfeiture and Arrangement (DS9)

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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA00872266: Apollo Management, Forfeiture and Arrangement (DS9)

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This document contains correspondence from Ada Clapp regarding Black Family Partners c/o Apollo Management discussing tax planning arrangements, specifically addressing concerns about a GRAT (Grantor Retained Annuity Trust) and potential forfeiture of assets if Leon defaults. The communication references IRS Circular 230 and discusses the tax implications of the proposed arrangement.

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🔑 Evidence Keywords

Apollo Management forfeiture arrangement

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Excerpt 1

Best regards, Ada Clapp Black Family Partners c/o **Apollo** **Management** IRS Circular 230 Disclosure: Pursuant to IRS regulations, I inform you that any tax

Excerpt 2

There is some concern that the gift to the GRAT would be incomplete given that there is a risk (albeit slight) of **forfeiture** of the assets if Leon defaults

Excerpt 3

There is some concern that this **arrangement** may disqualify the GRAT since the amount of the annuity payable to Leon or his estate would be uncertain and