EFTA02710057.pdf
dataset_11 pdf 80.7 KB • Feb 3, 2026 • 2 pages
From: Richard Joslin
Sent: Monday, September 15, 2014 4:06 PM
To: jeffrey E.
Subject: FW: Intercompany Loan Discussion
Attachments: Intercompany Loan Discussion - Final.pdf
I heard this mentioned in=the spring
<=p>
Public gets a note (recei=es interest income instead of partnership distributions)=/p>
Interest reduces APO Corp=tax income
Lower APO Corp taxable in=ome reduces corporate tax drag (and benefits of TRA goodwill amortization►=o:p>
Lower tax drag increases =NI which means Founders get more cash distribution from AGM (less in TRA)<=:p>
<=p>
Let's discuss after=9/1S/
<=p>
From: Katie =regory Newma
Sent: Monday, September 15, 2014 11:42 AM
To: Richard Joslin
Subject: Intercompany Loan Discussion
Hi Rich,
Hope all is well. L=on asked that I send you the attached presentation which is being consider=d by APO Corp. I had
mentioned this as a likely proposal when we last spoke. Please let me know if you would like to discuss.=/o:p>
Kind regards,<=span>
Katie</=>
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are addressed and may contain confidential and/or privileged </=re>
material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon this=/pre>
information by persons or entities other than the intended =/pre>
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