EFTA02700566.pdf
dataset_11 pdf 2.7 MB • Feb 3, 2026 • 27 pages
LEON D. BLACK - SS NO. 056-384069
SCHEDULE OF TAXABLE GIFTS MADE TO THE
JUDAH INVESTMENTS TRUSTS (A THRU K) - DEC 21, 2006
GRANTOR RETAINED ANNUITY TRUSTS
December 2006 (6.8%) year annuity Percent annuity amount
1 49.5683% $ 290,175,433.68
TOTAL FOR ALL 2 59.4820% $ 348,210,520.41
DECEMBER GRATS: 99.9900% $ 585,346,794.47
$ 585,405,335.00 initial FMV of trust
$ 585,346,794.47 retained interest 99.99%
58,540.53 taxable ift 0.01%
700.00%
Initial FMV 9f Trust Fund
460,000.00 Apollo Management III„ LP
1.420,000.00 Apollo Management IV, LP
3.690,000.00 Apollo Management V. LP
$ 45,600,000.00 Apollo Management VI, LP
$ 227,000,000.00 Apollo Investment Management, LP
9.600,000.00 Apollo Value Inv Fund Mgt., LP
$ 87.000.000 00 Apollo SW Management, LP
$ 20.800,000.00 Apollo Asia Management LP
$ 98.800,000.00 Apollo Europe Management LP
$ 80,500,000.00 Apollo Alternative Assets LP
$ 10,535.335.00 Apollo Adv VI LP 8, Apollo Adv. VI (EH) LP
$ 585,405,335.00 TOTAL
Judah Investment Trust A
December 2006 (5.8%)
year annu' y percent annuity amount
1 49.5683% $ 228,014.15
2 59.4820% $ 273.616.98
99.9900% $ 459,954.00
460,000.00 initial FMV of trust
459,954.00 retained interest
46.00 taxable gift
460,000.00 appraised value of 30.35% interest in Apollo Management ill LP
EFTA_R1_02067158
EFTA02700566
LEON D. BLACK • SS NO. 05638.1069
SCHEDULE OF TAXABLE GIFTS MADE TO THE
JUDAH INVESTMENTS TRUSTS (A THRU K) - DEC 21, 2006
GRANTOR RETAINED ANNUITY TRUSTS (CONTINUED) PG 2 OF 6
Judah Investment Trust B
December 2006 (5.8%)
year annuity Percent annuity amount
1 49.5683% $ 703,869.77
2 59.4820% $ 844.643.72
99.9900% $ 1 419 858 00
1,420,000.00 initial FMV of trust
$ 1.419.858.00 retained interest
142.00 taxable gilt
1.420.000.00 appraised value of 30.35% interest in Apollo Management IV, LP
Judah Investment Trust C
December 2006 (5.8%)
year annuity percent annuity amount
1 49.5683% $ 1,829,070.02
2 59.4820% S 2,194.884.03
99.9900% $ 3.689.631.00
3,690,000.00 initial FMV of trust
3.689.631.00 retained interest
369.00 taxable gift
3,690,000.00 appraised value of 30.35% interest in Apollo Management V. LP
Judah Investment Trust D
December 2006 (5.8%)
year annuity percent annuity amount
49.5683% $ 22,603,141 76
2 59.4820% $ 27.123,770.12
99.9900% $ 45.595,440.00_
$ 45,600,000.00 initial FMV of trust
S 45.595,440.00 retained interest
4,560.00 taxable gift
z=tietSisgMIRS...
S 45.600.000.00 appraised value of 30.35% interest in Apollo Management VI, LP
EFTA_R1_02067159
EFTA02700567
LEON D. BLACK - SS NO. 056.38.1069
SCHEDULE OF TAXABLE GIFTS MADE TO THE
JUDAH INVESTMENTS TRUSTS (A THRU K) - DEC 21, 2006
GRANTOR RETAINED ANNUITY TRUSTS (CONTINUED) PG 3 OF 5
Judah Investment Trust E
December 2006 (5.8%)
year annuity percent annuity amount
1 49.5683% $ 112,520,025.88
2 59.4820% S 135,024,031.06
99.9900% $ 226,977,300.00
$ 227.000.000.00 initial FMV of trust
$ 226,977.300.00 retained interest
22,700.00 taxable gift
S 227.000.000.00 appraised value of 26.8% interest in Apollo Investment Management. LP
Judah Investment Trust F
December 2006 (5.8%)
year annuity percent annuity amount
1 49.5683% $ 4,758,556.16
2 59.4820% $ 5 710,267.39
99.9900% S ?..599, 040.90
9,600,000 00 initial FMV of trust
9.599,040.00 retained interest
960.00 taxable gift
9,600,000.00 appraised value of 26.9% interest in Apollo Value Investment Fund Management. LP
Judah Investment Trust G
December 2006 (5.8%)
year pnnuitv percent annuity amount
1 49.5683% $ 43,124,415.21
2 59.4820% $ 51.749.298.25
99.9900% $ 86,991,300.00
87,000,000 00 initial FMV of trust
86,991,300.00 retained interest
8,700.00 taxable gift
87,000,000.00 appraised value of 44% interest in Apollo SVF Management, LP
EFTA_R1_02067160
EFTA02700568
LEON D. BLACK • SS NO. 056-38-1069
SCHEDULE OF TAXABLE GIFTS MADE TO THE
JUDAH INVESTMENTS TRUSTS (A THRU K) - DEC 21, 2006
GRANTOR RETAINED ANNUITY TRUSTS (CONTINUED) PG 4 OF 5
Judah Investment Trust H
December 2005 (5.8%)
year annuity percent annuity amount
1 49.5683% $ 10,310,205.01
2 59.4820% $ 12,372,246.02
99.9900% 20,7974920.00
20,800,000.00 initial FMV of trust
$ 20,797,920 00 retained interest
$ 2,080.00 taxable gift
20.800.000.00 appraised value of 44% interest in Apollo Asia Management, LP
Judah Investment Trust I
December 2006 (5.8%)
year annuity percent annuity amount
1 49.5683% $ 48,973,473.82
2 59.4820% $ 58,768,168.58
99.9900% $ 98,790 120 00
$ 98,800.000.00 initial FMV of trust
$ 98.790.120.00 retained interest
9,880.00 taxable rft
98,800,000.00 appraised value of 44% interest in Apollo Europe Management, LP
Judah Investment Trust J
December 2006 (5.8%)
year annuity percent annuity amount
1 49.5683% $ 39,902,476.14
2 59.4820% $ 47,882,971 37
99.9900% $ 80,491 950.00
80,500,000.00 initial FMV of trust
80,491,950.00 retained interest
8,050.00 taxable gift
80.500,000.00 appraised value of 44% interest in Apollo Alternative Assets, LP
EFTA_R1_02067161
EFTA02700569
LEON D. BLACK - SS NO. 056.38-1069
SCHEDULE OF TAXABLE GIFTS MADE TO THE
JUDAH INVESTMENTS TRUSTS (A THRU K) - DEC 21, 2006
GRANTOR RETAINED ANNUITY TRUSTS (CONTINUED) PG 5 OF 5
Judah Investment Trust K
December 2006 (5.8%)
year annuity percent annuity amount
1 49,5683% $ 5,222,185.76
2 59.4820% $ 6,266,622.91
99.9900% S 10,534,281.47
$ 10,535,335.00 initial FMV of trust
$ 10,534,281.47 retained interest
1,053.53 taxable gift
10,535,335.00 142 Points of Apollo Advisors VI and Apollo Advisors VI (EH)
EFTA_R1_02067162
EFTA02700570
LEON D. BLACK
Rider I to Form 709
United States Gift and Generation Skipping Transfer Tax Return
Calendar Year 2006
Social Security No. 056-38-1069
Disclosure Pursuant to Regulation Section 301.6501(c)-1(f)(2)
CONTRIBUTION TO JUDAH INVESTMENT TRUST A (Sch. A, Part 3, Item U
The transaction referred to as Item 1 on Schedule A, Part 3 of this Return represents the
contribution by Leon D. Black (the "Taxpayer") to the Judah Investment Trust A (the
"Trust"), created under trust agreement dated December 21, 2006 (the "Trust Creation Date")
between Leon D. Black, as senior, and Leon D. Black and John Hannan, as trustees (the
"Trust Agreement"). The Trust is a grantor-retained annuity trust in which the Taxpayer
retained a Qualified Interest, as_defined in §2707(h) oaLtheinktogRetiCJII/C Code (the
"Code"). A copy of the Trust Agreement is attached as Exhibit G-1.
Under the terms of the Trust Agreement, an annuity is payable from the Trust to the
Taxpayer (or, if the Taxpayer is not living, to the Taxpayer's estate) on the day before the
first anniversary of the Trust Creation Date, and on the day before the 2nd and final
anniversary of the Trust Creation Date during the Trust's 2-year term. The value of the first
annuity is equal to such percent of the fair market value of the trust fund of the Trust as
finally determined for federal gift tax purposes that, when increased by twenty (20%) percent
in the 2nd and final year of the 2-year term, results in the Taxpayer's right to receive the
annuity payments having a value equal to 99.99% of the fair market value of the trust fund of
the Trust as finally determined for federal gift tax purposes. The value of the second and
final annuity payable to the Taxpayer is equal to 120% of the value of the prior year's
annuity. The Trust ends on the day before the 2nd anniversary of the Trust Creation Date.
Upon the termination of the Trust, the remaining trust property will be distributed to the
trustees of the Black 2006 Family Trust (the "Family Trust"), to be added to the principal of
the Family Trust and disposed of therewith.
The value of the gift is determined by subtracting the value of the qualified annuity interest
from the value of the property contributed to the Trust. Under Treas. Reg. § 25.2702-2(b)(2),
the value of a qualified annuity interest is determined under Code § 7520.
Accordingly, for the transfer shown as Item 1 of Schedule A, Part 3 of the Return, there is
shown below (I) the valuation of the initial fair market value of the Trust, (2) the annuity
percentages taken from the Trust Agreement, (3) the annuity term taken from the Trust
Agreement, (4) the § 7520 rate in effect for the month in which the transfers occurred, (5) the
value of the qualified annuity and (6) the resulting gift.
NYB1520433WKWL6901LOOO26504.0001
EFTA_R1_02067163
EFTA02700571
On December 21, 2006, the Taxpayer contributed to the Trust a 30.35% limited partnership
interest in Apollo Management 111, LP, a Delaware limited partnership. The Taxpayer
received no consideration from the Trust in return for his contribution. Based on an appraisal
by Empire Valuation Consultants., a copy of which is attached as Exhibit G- I AP, on
December 21, 2006 the gift tax value of the 30.35% limited partnership interest in Apollo
Management III, LP the Taxpayer transferred to the Trust was $460,000.
(I) Initial Fair Market Value of the Trust Fund $460,000
(2) Annuity Rate Per Trust Agreement: 49.5683% in year 1; 59.4820% in
year 2
(3) Annuity Term Per Trust Agreement 2 Years
(4) Section 7520 Rate for Dec 2006 5.8%
(5) Value of Qualified Annuity $459,954
(6) Value of Gift $46.00
NY1:1132043:1101W/L69011.D0026504 0001 2
EFTA_R1_02067164
EFTA02700572
LEON D. BLACK
Rider 1 to Form 709
United States Gift and Generation Skipping Transfer Tax Return
Calendar Year 2006
Social Security No. 056-38-1069
Disclosure Pursuant to Regulation Section 301.6501(e)-1(f)(2)
CONTRIBUTION TO JUDAH INVESTMENT TRUST B (Sch. A, Part 3. Item 1)
The transaction referred to as Item 1 on Schedule A, Part 3 of this Return represents the
contribution by Leon D. Black (the "Taxpayer") to the Judah Investment Trust B (the
"Trust"), created under trust agreement dated December 21, 2006 (the "Trust Creation Date")
between Leon D. Black, as senior, and Leon D. Black and John Hannan, as trustees (the
"Trust Agreement"). The Trust is a grantor-retained annuity trust in which the Taxpayer
rehined_a_Qualitied hits-rest, as deciaesLin § 2702(b) of the Internal_Revenue_Code_(the
"Code"). A copy of the Trust Agreement is attached as Exhibit G-2.
Under the terms of the Trust Agreement, an annuity is payable from the Trust to the
Taxpayer (or, if the Taxpayer is not living, to the Taxpayer's estate) on the day before the
first anniversary of the Trust Creation Date, and on the day before the 2nd and final
anniversary of the Trust Creation Date during the Trust's 2-year term. The value of the first
annuity is equal to such percent of the fair market value of the trust fund of the Trust as
finally determined for federal gift tax purposes that, when increased by twenty (20%) percent
in the 2nd and final year of the 2-year term, results in the Taxpayer's right to receive the
annuity payments having a value equal to 99.99% of the fair market value of the trust fund of
the Trust as finally determined for federal gift tax purposes. The value of the second and
final annuity payable to the Taxpayer is equal to 120% of the value of the prior year's
annuity. The Trust ends on the day before the 2nd anniversary of the Trust Creation Date.
Upon the termination of the Trust, the remaining trust property will be distributed to the
trustees of the Black 2006 Family Trust (the "Family Trust"), to be added to the principal of
the Family Trust and disposed of therewith.
The value of the gift is determined by subtracting the value of the qualified annuity interest
from the value of the property contributed to the Trust. Under Treas. Reg. § 25.2702-2(6)(2),
the value of a qualified annuity interest is determined under Code § 7520.
Accordingly, for the transfer shown as Item 1 of Schedule A, Part 3 of the Return, there is
shown below (1) the valuation of the initial fair market value of the Trust, (2) the annuity
percentages taken from the Trust Agreement, (3) the annuity term taken from the Trust
Agreement, (4) the § 7520 rate in effect for the month in which the transfers occurred, (5) the
value of the qualified annuity and (6) the resulting gift.
NY I A1520433101W/L69011DOCU650/.0001
EFTA_R1_02067165
EFTA02700573
On December 21, 2006, the Taxpayer contributed to the Trust a 30.35% limited partnership
interest in Apollo Management IV LP, a Delaware limited partnership. The Taxpayer
received no consideration from the Trust in return for his contribution. Based on an appraisal
by Empire Valuation Consultants., a copy of which is attached as Exhibit G-2AP, on
December 21, 2006 the gift tax value of the 30.35% limited partnership interest in Apollo
Management IV, LP the Taxpayer transferred to the Trust was $1,420,000.
(1) Initial Fair Market Value of the Trust Fund $1,420,000
(2) Annuity Rate Per Trust Agreement: 49.5683% in year I; 59.4820% in
year 2
(3) Annuity Term Per Trust Agreement 2 Years
(4) Section 7520 Rate for December 2006 5.8%
(5) Value of Qualified Annuity $1,419,858
(6) Value of Gift $142.00
NY I A15204331.01W/1.69011.OOM6S04.O001 2
EFTA_R1_02067166
EFTA02700574
LEON D. BLACK
Rider 1 to Form 709
United States Gift and Generation Skipping Transfer Tax Return
Calendar Year 2006
Social Security No. 056-38-1069
Disclosure Pursuant to Regulation Section 301.6501(c)-1(f)(2)
CONTRIBUTION TO JUDAH INVESTMENT TRUST C (Sch. A. Part 3, Item 1)
The transaction referred to as Item I on Schedule A, Part 3 of this Return represents the
contribution by Leon D. Black (the "Taxpayer") to the Judah Investment Trust C (the
"Trust"), created under trust agreement dated December 21, 2006 (the "Trust Creation Date")
between Leon D. Black, as settlor, and Leon D. Black and John Hannan, as trustees (the
"Trust Agreement"). The Trust is a grantor-retained annuity trust in which the Taxpayer
tetaineta Qualified inieresiasseingsljn_L2INCbLoi the...lotArnaLRsxentic..Code (the
"Code"). A copy of the Trust Agreement is attached as Exhibit G-3.
Under the terms of the Trust Agreement, an annuity is payable from the Trust to the
Taxpayer (or, if the Taxpayer is not living, to the Taxpayer's estate) on the day before the
first anniversary of the Trust Creation Date, and on the day before the 2nd and final
anniversary of the Trust Creation Date during the Trust's 2-year term. The value of the first
annuity is equal to such percent of the fair market value of the trust fund of the Trust as
finally determined for federal gift tax purposes that, when increased by twenty (20%) percent
in the 2nd and final year of the 2-year term, results in the Taxpayer's right to receive the
annuity payments having a value equal to 99.99% of the fair market value of the trust fund of
the Trust as finally determined for federal gift tax purposes. The value of the second and
final annuity payable to the Taxpayer is equal to 120% of the value of the prior year's
annuity. The Trust ends on the day before the 2nd anniversary of the Trust Creation Date.
Upon the termination of the Trust, the remaining trust property will be distributed to the
trustees of the Black 2006 Family Trust (the "Family Trust"), to be added to the principal of
the Family Trust and disposed of therewith.
The value of the gift is determined by subtracting the value of the qualified annuity interest
from the value of the property contributed to the Trust. Under Treas. Reg. § 25.2702-2(6)(2),
the value of a qualified annuity interest is determined under Code § 7520.
Accordingly, for the transfer shown as Item 1 of Schedule A, Part 3 of the Return, there is
shown below (I) the valuation of the initial fair market value of the Trust, (2) the annuity
percentages taken from the Trust Agreement„ (3) the annuity term taken from the Trust
Agreement, (4) the § 7520 rate in effect for the month in which the transfers occurred, (5) the
value of the qualified annuity and (6) the resulting gift.
NY I:II 520413l0RWL6901IDOCU6504.0001
EFTA_R1_02067167
EFTA02700575
On December 21, 2006, the Taxpayer contributed to the Trust a 30.35% limited partnership
interest in Apollo Management V, LP, a Delaware limited partnership. The Taxpayer
received no consideration from the Trust in return for his contribution. Based on art appraisal
by Empire Valuation Consultants., a copy of which is attached as Exhibit G-3AP, on
December 21, 2006 the gift tax value of the 30.35% limited partnership interest in Apollo
Management V, LP the Taxpayer transferred to the Trust was $3,690,000.
(1) Initial Fair Market Value of the Trust Fund S3,690,000
(2) Annuity Rate Per Trust Agreement: 49.5683% in year I; 59.4820% in
year 2
(3) Annuity Term Per Trust Agreement 2 Years
(4) Section 7520 Rate for December 2006 5.8%
(5) Value of Qualified Annuity $3,689,631.00
(6) Value of Gift $369.00
NYIMS21243341W/149011DOC126501.0001 2
EFTA_R1_02067168
EFTA02700576
LEON D. BLACK
Rider I to Form 709
United States Gift and Generation Skipping Transfer Tax Return
Calendar Year 2006
Social Security No. 056-38-1069
Disclosure Pursuant to Regulation Section 301.6501(c)-1(f)(2)
CONTRIBUTION TO JUDAH INVESTMENT TRUST D (Sch. A, Part 3, Item 1)
The transaction referred to as Item 1 on Schedule A, Part 3 of this Return represents the
contribution by Leon D. Black (the "Taxpayer") to the Judah Investment Trust D (the
"Trust"), created under trust agreement dated December 21, 2006 (the "Trust Creation Date")
between Leon D. Black, as settlor, and Leon D. Black and John Hannan, as trustees (the
"Trust Agreement"). The Trust is a grantor-retained annuity trust in which the Taxpayer
retained a Qualified interest as_defirmun § 270201 of
the Internal Revenue Code _(the
"Code"). A copy of the Trust Agreement is attached as Exhibit G-4.
Under the terms of the Trust Agreement, an annuity is payable from the Trust to the
Taxpayer (or, if the Taxpayer is not living, to the Taxpayer's estate) on the day before the
first anniversary of the Trust Creation Date, and on the day before the 2nd and final
anniversary of the Trust Creation Date during the Trust's 2-year term. The value of the first
annuity is equal to such percent of the fair market value of the trust fund of the Trust as
finally determined for federal gift tax purposes that, when increased by twenty (20%) percent
in the 2nd and final year of the 2-year term, results in the Taxpayer's right to receive the
annuity payments having a value equal to 99.99% of the fair market value of the trust fund of
the Trust as finally determined for federal gift tax purposes. The value of the second and
final annuity payable to the Taxpayer is equal to 120% of the value of the prior year's
annuity. The Trust ends on the day before the 2nd anniversary of the Trust Creation Date.
Upon the termination of the Trust, the remaining trust property will be distributed to the
trustees of the Black 2006 Family Trust (the "Family Trust"), to be added to the principal of
the Family Trust and disposed of therewith.
The value of the gift is determined by subtracting the value of the qualified annuity interest
from the value of the property contributed to the Trust. Under Treas. Reg. § 25.2702-2(6)(2),
the value of a qualified annuity interest is determined under Code § 7520.
Accordingly, for the transfer shown as Item 1 of Schedule A, Part 3 of the Return, there is
shown below (I) the valuation of the initial fair market value of the Trust, (2) the annuity
percentages taken from the Trust Agreement, (3) the annuity term taken from the Trust
Agreement, (4) the § 7520 rate in effect for the month in which the transfers occurred, (5) the
value of the qualified annuity and (6) the resulting gift.
NYIA1510433*IML69011.00O26504.0001
EFTA_R1_02067169
EFTA02700577
On December 21, 2006, the Taxpayer contributed to the Trust a 30.35% limited partnership
interest in Apollo Management VI, LP, a Delaware limited partnership. The Taxpayer
received no consideration from the Trust in return for his contribution. Based on an appraisal
by Empire Valuation Consultants., a copy of which is attached as Exhibit G-4AP, on
December 21, 2006 the gift tax value of the 30.35% limited partnership interest in Apollo
Management VI, LP the Taxpayer transferred to the Trust was $45,600,000.
(1) Initial Fair Market Value of the Trust Fund $45,600,000
(2) Annuity Rate Per Trust Agreement: 49.5683% in year 1; 59.4820% in
year 2
(3) Annuity Term Per Trust Agreement 2 Years
(4) Section 7520 Rate for December 2006 5.8%
(5) Value of Qualified Annuity $45,595,440
(6) Value of Gift $4,560.00
NYI US2013PORW1.69011DOC\16504 0001 2
EFTA_R1_02067170
EFTA02700578
LEON D. BLACK
Rider 1 to Form 709
United States Gift and Generation Skipping Transfer Tax Return
Calendar Year 2006
Social Security No. 056-38-1069
Disclosure Pursuant to Regulation Section 301.6501(c)-1(O(2)
CONTRIBUTION TO JUDAH INVESTMENT TRUST E (Sch. A. Part 3. Item 1)
The transaction referred to as Item 1 on Schedule A, Part 3 of this Return represents the
contribution by Leon D. Black (the "Taxpayer") to the Judah Investment Trust E (the
"Trust"), created under trust agreement dated December 21, 2006 (the "Trust Creation Date")
between Leon D. Black, as settlor, and Leon D. Black and John Hannan, as trustees (the
"Trust Agreement"). The Trust is a grantor-retained annuity trust in which the Taxpayer
retained a Q.ualified_Interest—as defined in § 2702(h) of ineinternal Revenue Code_(the
"Code"). A copy of the Trust Agreement is attached as Exhibit O-5.
Under the terms of the Trust Agreement, an annuity is payable from the Trust to the
Taxpayer (or, if the Taxpayer is not living, to the Taxpayer's estate) on the day before the
first anniversary of the Trust Creation Date, and on the day before the 2nd and final
anniversary of the Trust Creation Date during the Trust's 2-year term. The value of the first
annuity is equal to such percent of the fair market value of the trust fund of the Trust as
finally determined for federal gift tax purposes that, when increased by twenty (20%) percent
in the 2nd and final year of the 2-year term, results in the Taxpayer's right to receive the
annuity payments having a value equal to 99.99% of the fair market value of the trust fund of
the Trust as finally determined for federal gift tax purposes. The value of the second and
final annuity payable to the Taxpayer is equal to 120% of the value of the prior year's
annuity. The Trust ends on the day before the 2nd anniversary of the Trust Creation Date.
Upon the termination of the Trust, the remaining trust property will be distributed to the
trustees of the Black 2006 Family Trust (the "Family Trust"), to be added to the principal of
the Family Trust and disposed of therewith.
The value of the gift is determined by subtracting the value of the qualified annuity interest
from the value of the property contributed to the Trust. Under Treas. Reg. § 25.2702-2(6)(2),
the value of a qualified annuity interest is determined under Code § 7520.
Accordingly, for the transfer shown as Item 1 of Schedule A, Part 3 of the Return, there is
shown below (1) the valuation of the initial fair market value of the Trust, (2) the annuity
percentages taken from the Trust Agreement, (3) the annuity term taken from the Trust
Agreement, (4) the § 7520 rate in effect for the month in which the transfers occurred, (5) the
value of the qualified annuity and (6) the resulting gift.
NY111520133‘011WL69011.00026504.0001
EFTA_R1_02067171
EFTA02700579
On December 21, 2006, the Taxpayer contributed to the Trust a 26.8% limited partnership
interest in Apollo Investment Management LP, a Delaware limited partnership. The
Taxpayer received no consideration from the Trust in return for his contribution. Based on
an appraisal by Empire Valuation Consultants., a copy of which is attached as Exhibit G-
5AP, on December 21, 2006 the gift tax value of the 26.8% limited partnership interest in
Apollo Investment Management LP the Taxpayer transferred to the Trust was $227,000,000.
(1) Initial Fair Market Value of the Trust Fund $227,000,000
(2) Annuity Rate Per Trust Agreement: 49.5683% in year 1; 59.4820% in year 2
(3) Annuity Term Per Trust Agreement 2 Years
(4) Section 7520 Rate for December 2006 5.8%
(5) Value of Qualified Annuity $226,977,300
(6) Value of Gift $22,700.00
NY1:152003‘01W/L690”.D0026304.000I 2
EFTA_R1_02067172
EFTA02700580
fg)
LEON D. BLACK
Rider I to Form 709
United States Gift and Generation Skipping Transfer Tax Return
Calendar Year 2006
Social Security No. 056-38-1069
Disclosure Pursuant to Regulation Section 301.6501(c)- I (f)(2)
CONTRIBUTION TO JUDAH INVESTMENT TRUST F (Sch. A. Part 3. Item 1)
The transaction referred to as Item 1 on Schedule A, Part 3 of this Return represents the
contribution by Leon D. Black (the "Taxpayer") to the Judah Investment Trust F (the
"Trust"), created under trust agreement dated December 21, 2006 (the "Trust Creation Date")
between Leon D. Black, as settlor, and Leon D. Black and John Hannan, as trustees (the
"Trust Agreement"). The Trust is a grantor-retained annuity trust in which the Taxpayer
retabacsLi QualifiettInt_CICASSIefilltd_in. §_2702.(b) of theinternal .Re.verttle C0.cle (the. ___
"Code"). A copy of the Trust Agreement is attached as Exhibit G-6.
Under the terms of the Trust Agreement, an annuity is payable from the Trust to the
Taxpayer (or, if the Taxpayer is not living, to the Taxpayer's estate) on the day before the
first anniversary of the Trust Creation Date, and on the day before the 2nd and final
anniversary of the Trust Creation Date during the Trust's 2-year term. The value of the first
annuity is equal to such percent of the fair market value of the trust fund of the Trust as
finally determined for federal gift tax purposes that, when increased by twenty (20%) percent
in the 2nd and final year of the 2-year term, results in the Taxpayer's right to receive the
annuity payments having a value equal to 99.99% of the fair market value of the trust fund of
the Trust as finally determined for federal gift tax purposes. The value of the second and
final annuity payable to the Taxpayer is equal to 120% of the value of the prior year's
annuity. The Trust ends on the day before the 2nd anniversary of the Trust Creation Date.
Upon the termination of the Trust, the remaining trust property will be distributed to the
trustees of the Black 2006 Family Trust (the "Family Trust"), to be added to the principal of
the Family Trust and disposed of therewith.
The value of the gift is determined by subtracting the value of the qualified annuity interest
from the value of the property contributed to the Trust. Under Treas. Reg. § 25.2702-2(b)(2),
the value of a qualified annuity interest is determined under Code § 7520.
Accordingly, for the transfer shown as Item 1 of Schedule A, Part 3 of the Return, there is
shown below (1) the valuation of the initial fair market value of the Trust, (2) the annuity
percentages taken from the Trust Agreement, (3) the annuity term taken from the Trust
Agreement, (4) the § 7520 rate in effect for the month in which the transfers occurred, (5) the
value of the qualified annuity and (6) the resulting gift.
NY 1:11520433`.011W1.4901!.0OC26501.0001
EFTA_R1_02067173
EFTA02700581
On December 21, 2006, the Taxpayer contributed to the Trust a 26.9% limited partnership
interest in Apollo Value Investment Fund Management LP, a Delaware limited partnership.
The Taxpayer received no consideration from the Trust in return for his contribution. Based
on an appraisal by Empire Valuation Consultants., a copy of which is attached as Exhibit G-
6AP, on December 21, 2006 the gift tax value of the 26.9% limited partnership interest in
Apollo Value Investment Fund Management LP the Taxpayer transferred to the Trust was
$9,600,000.
(1) Initial Fair Market Value of the Trust Fund $9,600,000
(2) Annuity Rate Per Trust Agreement: 49.5683% in year I; 59.4820% in
year 2
(3) Annuity Term Per Trust Agreement 2 Years
(4) Section 7520 Rate for December 2006 5.8%
(5) Value of Qualified Annuity $9,599,040
(6) Value of Gift $960
NY1.3152041.1t0IM.690111)0026504.0001 2
EFTA_R1_02067174
EFTA02700582
LEON D. BLACK
Rider to Form 709
United States Gift and Generation Skipping Transfer Tax Return
Calendar Year 2006
Social Security No. 056-38-1069
Disclosure Pursuant to Regulation Section 301.6501(c)-1(f)(2)
CONTRIBUTION TO JUDAH INVESTMENT TRUST G (Sch. A, Part 3, Item I)
The transaction referred to as Item I on Schedule A, Part 3 of this Return represents the
contribution by Leon D. Black (the "Taxpayer") to the Judah Investment Trust G (the
"Trust"), created under trust agreement dated December 21, 2006 (the "Trust Creation Date")
between Leon D. Black, as settlor, and Leon D. Black and John Hannan, as trustees (the
"Trust Agreement"). The Trust is a grantor-retained annuity trust in which the Taxpayer
retainecl-&-Qualified-Interestras_definerl in § 2702(h) of the Internal Reyenue_Code (the_
"Code"). A copy of the Trust Agreement is attached as Exhibit G-7.
Under the terms of the Trust Agreement, an annuity is payable from the Trust to the
Taxpayer (or, if the Taxpayer is not living, to the Taxpayer's estate) on the day before the
first anniversary of the Trust Creation Date, and on the day before the 2nd and final
anniversary of the Trust Creation Date during the Trust's 2-year term. The value of the first
annuity is equal to such percent of the fair market value of the trust fund of the Trust as
finally determined for federal gift tax purposes that, when increased by twenty (20%) percent
in the 2nd and final year of the 2-year term, results in the Taxpayer's right to receive the
annuity payments having a value equal to 99.99% of the fair market value of the trust fund of
the Trust as finally determined for federal gift tax purposes. The value of the second and
final annuity payable to the Taxpayer is equal to 120% of the value of the prior year's
annuity. The Trust ends on the day before the 2nd anniversary of the Trust Creation Date.
Upon the termination of the Trust, the remaining trust property will be distributed to the
trustees of the Black 2006 Family Trust (the "Family Trust"), to be added to the principal of
the Family Trust and disposed of therewith.
'The value of the gift is determined by subtracting the value of the qualified annuity interest
from the value of the property contributed to the Trust. Under Treas. Reg. § 25.2702-2(b)(2),
the value of a qualified annuity interest is determined under Code § 7520.
Accordingly, for the transfer shown as Item 1 of Schedule A, Part 3 of the Return, there is
shown below (1) the valuation of the initial fair market value of the Trust, (2) the annuity
percentages taken from the Trust Agreement, (3) the annuity term taken from the Trust
Agreement, (4) the § 7520 rate in effect for the month in which the transfers occurred, (5) the
value of the qualified annuity and (6) the resulting gift.
NY1:11$20433‘011WL6901!DOCk26$04.0001
EFTA_R1_02067175
EFTA02700583
On December 21, 2006, the Taxpayer contributed to the Trust a 44% limited partnership
interest in Apollo SVF Management LP, a Delaware limited partnership. The Taxpayer
received no consideration from the Trust in return for his contribution. Based on an appraisal
by Empire Valuation Consultants., a copy of which is attached as Exhibit G-7AP, on
December 21, 2006 the gift tax value of the 44% limited partnership interest in Apollo SVF
Management LP the Taxpayer transferred to the Trust was $87,000,000
(I) Initial Fair Market Value of the Trust Fund $87,000,000
(2) Annuity Rate Per Trust Agreement: 49.5683% in year 1; 59.4820% in
year 2
(3) Annuity Term Per Trust Agreement 2 Years
(4) Section 7520 Rate for June 2004 5.8%
(5) Value of Qualified Annuity $86,991,300
(6) Value of Gift $8,700.00
NYI:‘1320133WIML6901!.D0026504.0001 2
EFTA_R1_02067176
EFTA02700584
LEON D. BLACK
Rider 1 to Form 709
United States Gift and Generation Skipping Transfer Tax Return
Calendar Year 2006
Social Security No. 056-38-1069
Disclosure Pursuant to Regulation Section 301.650I(c)-1(O(2)
CONTRIBUTION TO JUDAH INVESTMENT TRUST H (Sch. A, Part 3, Item 1)
The transaction referred to as Item 1 on Schedule A, Part 3 of this Return represents the
contribution by Leon D. Black (the "Taxpayer") to the Judah Investment Trust H (the
"Trust"), created under trust agreement dated December 21, 2006 (the "Trust Creation Date")
between Leon D. Black, as senior, and Leon D. Black and John Hannan, as trustees (the
"Trust Agreement"). The Trust is a grantor-retained annuity trust in which the Taxpayer
retained a Qualified interest, as_defined in_42702(h) of Intemal Code (the
"Code"). A copy of the Trust Agreement is attached as Exhibit G-8.
Under the terms of the Trust Agreement, an annuity is payable from the Trust to the
Taxpayer (or, if the Taxpayer is not living, to the Taxpayer's estate) on the day before the
first anniversary of the Trust Creation Date, and on the day before the 2nd and final
anniversary of the Trust Creation Date during the Trust's 2-year term. The value of the first
annuity is equal to such percent of the fair market value of the trust fund of the Trust as
finally determined for federal gift tax purposes that, when increased by twenty (20%) percent
in the 2nd and final year of the 2-year term, results in the Taxpayer's right to receive the
annuity payments having a value equal to 99.99% of the fair market value of the trust fund of
the Trust as finally determined for federal gift tax purposes. The value of the second and
final annuity payable to the Taxpayer is equal to 120% of the value of the prior year's
annuity. The Trust ends on the day before the 2nd anniversary of the Trust Creation Date.
Upon the termination of the Trust, the remaining trust property will be distributed to the
trustees of the Black 2006 Family Trust (the "Family Trust"), to be added to the principal of
the Family Trust and disposed of therewith.
The value of the gift is determined by subtracting the value of the qualified annuity interest
from the value of the property contributed to the Trust. Under Treas. Reg. § 25.2702-2(b)(2),
the value of a qualified annuity interest is determined under Code § 7520.
Accordingly, for the transfer shown as Item 1 of Schedule A, Part 3 of the Return, there is
shown below (1) the valuation of the initial fair market value of the Trust, (2) the annuity
percentages taken from the Trust Agreement, (3) the annuity term taken from the Trust
Agreement, (4) the § 7520 rate in effect for the month in which the transfers occurred, (5) the
value of the qualified annuity and (6) the resulting gift.
N Y I A1520433$01M.69011.DOW6504.0001
EFTA_R1_02067177
EFTA02700585
On December 21, 2006, the Taxpayer contributed to the Trust a 44% limited partnership
interest in Apollo Asia Management LP, a Delaware limited partnership. The Taxpayer
received no consideration from the Trust in return for his contribution. Based on an appraisal
by Empire Valuation Consultants., a copy of which is attached as Exhibit G-8AP, on
December 21, 2006 the gift tax value of the 44% limited partnership interest in Apollo Asia
Management LP the Taxpayer transferred to the Trust was $20,800,000.
(1) Initial Fair Market Value of the Trust Fund $20,800,000
(2) Annuity Rate Per Trust Agreement: 49.5683% in year 1; 59.4820% in
year 2
(3) Annuity Term Per Trust Agreement 2 Years
(4) Section 7520 Rate for December 2006 5.8%
(5) Value of Qualified Annuity $20,797,920
(6) Value of Gift $2,080.00
NYIA1520133101W/LEADI! D0026504.0001 2
EFTA_R1_02067178
EFTA02700586
LEON D. BLACK
Rider 1 to Fonn 709
United States Gift and Generation Skipping Transfer Tax Return
Calendar Year 2006
Social Security No. 056-38-1069
Disclosure Pursuant to Regulation Section 301.6501(c)-1(f)(2)
CONTRIBUTION TO JUDAH INVESTMENT TRUST I (Sch. A. Part 3. Item 1)
The transaction referred to as Item 1 on Schedule A, Part 3 of this Return represents the
contribution by Leon D. Black (the "Taxpayer") to the Judah Investment Trust I (the
"Trust"), created u
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