Foini 8858 gley. December 2013)

Foini 8858 gley. December 2013) Oepartment of the TleavoY Internal Revenue Service Name of person filing this retu n Filer's identifying number LEON D. & DEBRA BLACK Information Return of U.S. Persons With Respect To Foreign Disregarded Entities Ile Information about Form 8858 and Its separate Instructions Is at vAvw.Irs.gov/form8858. Information furnished for the foreign disregarded entitys annual accounting period (see instructions) beginning JAN 1 .2013 . and ending DEC 31 . 20 1 3OMB No. 1545-1910 Attachment Sequence No. 140 Number. stree and room or suite no. or P.O. box number it mail is not delivered to street address) Filer's tax year beginning JAN 20 13 , and ending DEC 31 .2013 Important Fill in all applicable lines and schedules. All information must be in English. All amounts must be stated in U.S. dollars unless otherwise indicated. to Name and address of foreign disregarded entity JMWT TOPCO LIMITED REGENTS WHARF, ALL SAINTS ST LONDON FC N1 9 UNITED KINGDOM bey, if any b(2) Reference ID number (see instructions) c Country(ies) under whose laws organized and entity type under local tax law UNITED KINGDOM CORPORATION d Date(s) of organization 09 28 12 e Effective date as foreign disregarded entity 09/28/12 f If benefits under a U.S. tax treaty were claimed with respect to income of the foreign disregarded entity, enter the treaty and article number g Country in which principal business activity is conducted UNITED KINGDOM h Principal business activity INVESTMENT INVESTMENT I Functional currency UNITED KINGDOM,POUND 2 Provide the following information for the foreign disregarded entity's a counting period stated above. a Name, address, and identifying number of branch office or agent (if any) in the b Name and addrmn Mowing corpecatO depalment. It amenable) of person(e)with CIAStOdY or the b00kd cgOortZ: Ct tha ttypOn adeggardni entity. and the location al such bOOKS United States and records. i1 °event ANDREW PRICE REGENTS WHARF, ALL SAINTS ST LONDON, FC N1 9PA UNITED KINGDOM 3 For the tax owner of the foreign disregarded entity (if different from the filer) provide the following: a Name and address f?% b Annual accounting period covered by the return (see instructions) c(1) U.S. identifying number, if any 02) Reference ID number (see instructio s) d Country under whose laws organized e Functional currency 4 For the direct owner of the foreign disregarded entity (if different from the tax owner provide the following: a Name and address b Country under whose laws organized JMWT ACQUISITION LLP REGENTS WHARF, ALL SAINTS ST UNITED KINGDOM LONDON, FC N1 9PA UNITED KINGDOM 5 if any I d Functional currency 'UNITED KINGDOM, PO Attach en I:idolization,' chart that identities the name. placement. percentageof ownership. tax classification. andcounty cd organization of all entities in the chain of ownership behtten the tax Peeler and the loreIgn disregarded entity. and the chore ol ownership between the loreir dieregarded entity end each entity In which the Welch disregarded entity Ninth% or more direct or :Wiwi Interco'. See inelluclicne. SEE STATEMENT 77 For Paperwork Reduction Act Notice, see the separate instructions. Form 8858 (Rev. 12-2013) 312411 12-10.13 LHA 13061007 133415 T-1009 518 2013.04030 BLACK, LEON T-10094 EFTA01114674 LEON D. & DEBRA BLACK Form 8858 (Rev. 12-2013) Page 2 lSchedule C [ Income Statement (see instructions) Important Report ail information in functional currency in accordance with U.S. GAAP. Also, report each amount in U.S. dollars translated from functional currency (using GAAP translation rules or the average exchange rate determined under section 989(b)). If the functional currency is the U.S. dollar. complete only the U.S. Dollars column. See instructions for special rules for foreign disregarded entities that use DAS TM. If you are using the average exchange rate (determined under section 989(b)), check the following box Functional Currency U.S. Dollars I Gross receipts or sales (net of returns and allowances) 1 2 Cost of goods sold 2 3 Gross profit (subtract line 2 from line 1) 3 4 Other income 4 5 Total income (add Ines 3 and 4) 5 6 Total deductions 6 7 Other adjustments 7 8 Net income (loss) per books 8 Schedule C-1 I Section 987 Gain or Loss Information (a) (b) Note. See the instructions if there are multiple recipients of remittances from the foreign disregarded entity. Amount stated in functional currency of foreign disregarded entity Amount stated in functional currency of recipient 1 Remittances from the foreign disregarded entity 2 Section 987 gain (loss) of recipient 2 Yes No 3 Were all remittances from the foreign disregarded entity treated as made to the direct owner? 4 Did the tax owner change its method of accounting for section 987 gain or loss with respect to remittances from the gweign disregarded entity during the tax year? Schedule F I Balance Sheet Important Report all amounts kt U.S. dollars computed in functional currency and translated into U.S. dollars in accords See instructions for an exception for foreign disregarded entities that use DASTM. with U.S. GAAP. Assets I Cash and other current assets 2 Other assets Ova Liabilities and y 3 Total assets "ivy N, 4 Liabilities 5 Owner's equity 6 Total liabilities and oymer's equity 1 Schedule G I Other Information Beginning annual accounting period End of annual accounting period 1 2 3 44,449,838. 44,449,838. 45,404,959. 45,404,959. 4 5 6 44,449,838. 44,449,838. 45,404,959. 45,404,959. I During the tax year, did the foreign disregarded entity own an interest in any trust? 2 During the tax year, did the foreign disregarded entity own at least a 10% interest, directly or indirectly, in any foreign partnership? 3 Answer the following question only if the foreign disregarded entity made its Section to be treated as disregarded from Its owner during the tax year: Did the tax owner claim a loss with respect to stock or debt of the foreign disregarded entity as a result of the election? 4 If the interest in the foreign disregarded entity is a separate unit under Reg. 1.1503(d)-1(bX4) or part of a combined separate unit under reg. 1.1503(d)-1(bX4)(ii) does the separate unit or combined separate unit have a dual consoidated loss as defined in Reg. 1.1503(d)-1(b)(5)(10? If 'Yes: enter the amount of the dual consolidated $ Answer question 5a. Yes No X X N /A Form 8858 (Rev. 12-2013) 519 13061007 133415 T-1009 2013.04030 BLACK, LEON T-10094 EFTA01114675 LEON D. & DEBRA BLACK Form 8858 (Rev. 12-2013) Schedule G I Other Information (continued) Page 3 5a Was any portion of the dual consolidated loss in question 4 taken into account in computing consolidated taxable income for the year? If "Yes; go to 5b. 'No; skip 5b and 5c b Was this permitted domestic use of the dual consolidated loss under Reg. 1.1503(d)-6? If 'Yes, see instructions and skip 5c. It"No," go to 5c c If this was not a permitted domestic use, was the dual consolidated loss used to compute consolidated taxable income as provided under Reg. 1.503(d)-4? If "Yes; enter the separate unit's contribution to the cumulative consolidated Taxable income (cumulative register) as of the beginning of the lax year Ne. $ See Instructions. 6 During the tax year, did the foreign disregarded entity pay or accrue any foreign tax that was disqualified for credit under section 901(m)? 7 During the tax year, did the foreign disregarded entity pay or accrue foreign taxes to which section 909 applies, or treat foreign taxes that were previously suspended under section 909 as no longer suspended? 8 Answer the following question only if the tag owner of the foreign disregarded entity k a controlled foreign corporation (CFC): Were there any intracompany transactions between the foreign disregarded entity and the CFC or any other branch of the CFC during the tax year, in which the foreign disregarded entity acted as a manufacturing, selling, or purchasing branch? Current Earnings and Profits or Taxable Income (see instructions) Schedule H Important Enter the amounts on lines 7 through 6 in functional currency. I Current year net income or (loss) per foreign books of account 2 Total net additions 3 Total net subtractions 4 Current earnings and profits (or taxable income — see instructions) (Iine 1 plus ire 2 us line 3) 5 DASTM gain or loss (if applicable) 6 Combine lines 4 and 5 7 Current earnings and profits (or taxable income) in U.S. doNars eine 6 translated at the average exchange rate determined under section 989(b) and the related regulations (see instructions)) Enter exchange rate used for line 7 ► Yes No 40;71 2 3 4 5 6 7 Form 8858 (Rev. 12-2013) 31,413 V-10.13 520 13061007 133415 T-1009 2013.04030 BLACK, LEON T-10094 EFTA01114676 Foini 8858 December 2013) Oepartment of the if esan Internal Revenue Service Name of person filing this retu n LEON D. & DEBRA BLACK I Information Return of U.S. Persons With Respect To Foreign Disregarded Entities Ile Information about Form 8858 and its separate Instructions Is at vAvw.irs.gov/form8858. Information furnished for the foreign disregarded entitys annual accounting period (see instructions) men beginning JAN 1 .2013 . and ending DEC 31 OMB No. 1545-1910 number if mail is not delivered to street address) Filers tax year beginning , 20 13 , and ending DEC 31 .20 13 Important Fill in all applicable lines and schedules. All information must be in English. All amounts must be stated in U.S. dollars unless otherwise indicated. to Name and address of foreign disregarded entity JMWT MIDCO LIMITED REGENTS WHARF, ALL SAINTS ST LONDON FC Ni 9 UNITED KINGDOM " b 1 U.S. iden n number if any b(2) Reference ID number (see instructions) c Coo ntry(ies) under whose laws organized and entity type under local tax law UNITED KINGDOM CORPORATION d Date(s) of organization 09 12 12 e Effective date as foreign disregarded entity 09/12/12 1 If benefits under a U.S. tax treaty were claimed with respect to income of the foreign disregarded entity, enter the treaty and article number g Country in which principal business activity is conducted UNITED KINGDOM h Principal business activity INVESTMENT I Functional currency UNITED KINGDOM, POUND 2 Provide the following information for the foreign disregarded entity's a counting period stated above. a Name, address, and identifying number of branch office or agent (if any) in the b Name and addrmn M owing corpecatO d.palmant. appladable) 01 person(S) with CufStOclY CA MO bOOkdani .A0OftZ: CI Cho ttypOn LICAggard9CI entity. and the Iccallon a such WOKS United States and recycle. if afferent ANDREW PRICE REGENTS WHARF, ALL SAINTS ST LONDON, FC Ni 9PA UNITED KINGDOM 3 For the tax owner of the foreign disregarded entity (if different from the filer) provide the (okaying: a Name and address Pb Annual accounting period covered by the return (see instructions) c(1) U.S. identifying number, if any c(2) Reference ID number (see instructio s) d Country under whose laws organized e Functional currency 4 For the direct owner of the foreign disregarded entity (if different from the tax owner provide the following: a Name and address JMWT TOPCO LIMITED REGENTS WHARF, ALL SAINTS ST LONDON, FC Ni 9PA UNITED KINGDOM b Country under whose laws organized ITED KINGDOM c U.S. identi n number, if any KTFunctional currency ITED KINGDOM, PO 5 Attach an cifprizatronal chart that identifies the note. placement. percentage of ownership. tax asssilication, and county of crganization of all entities in the chain of ownership betwaen the tax owner and the lorggn disregarded entity. and the chain al CumerilhiP between the loreigi disregarded entity and each entity In which the foreir disregarded entity hese 10% or more direct or :Wiwi 'Mortal. See inatiuclicns. SEE STATEMENT 78 For Paperwork Reduction Act Notice, see the separate Instructions. Form 8858 (Rev. 12-2013) 312411 12-10.13 IHA 13061007 133415 T-1009 521 2013.04030 BLACK, LEON T-10094 EFTA01114677 LEON D. & DEBRA BLACK Form 8858 (Rev. 12-2013) Page 2 Schedule C I Income Statement (see instructions) Important Report all information in functional currency in accordance with U.S. GAAP. Also, report each amou—nitn U.S. dollars transla functional currency (using GAAP translation rules or the average exchange rate determined under section 989(b)). If the functional currency is the U.S. dollar. complete only the U.S. Dollars column. See instructions for special rules for foreign disregarded entities that use DASTM. If you are using the average exchange rate (determined under section 989(b)), check the following box Functional Currency U.S. Dollars 1 Gross receipts or sales (net of returns and allowances) 1 2 Cost of goods sold 2 3 Gross profit (subtract line 2 from line 1) 3 4 Other income 4 5 Total income (add Ines 3 and 4) 5 6 Total deductions 6 7 Other adjustments 7 8 Net income (loss) per books 8 I-Schedule C-1 I Section 987 Gain or Loss Information (a) (b) Note. See the instructions if there are multiple recipients of remittances from the foreign disregarded entity. Amount stated in functional currency of foreign disregarded entity Amount stated in functional currency of recipient 1 Remittances from the foreign disregarded entity 2 Section 987 gain (loss) of recipient 2 Yes No 3 Were all remittances from the foreign disregarded entity treated as made to the direct owner? 4 Did the tax owner change its method of accounting for section 987 gain or loss with respect to remittances from the foreign disregarded entity during the tax year? .. Schedule F I Balance Sheet Important Report all amounts in U.S. dollars computed in functional currency and translated into U.S. dollars in accordance with U.S. GAAP. See instructions loran exception for foreign disregarded entities that use DASTM. Assets Beginning of annual accounting period ( End of annual accounting period 1 Cash and other current assets kiimut1 2 Other assets 3 Total assets 2 66,674,757. 68,107,438. 3 66,674,757. 68,107,438. Liabilities Car:nefifty % and 4 Liabilities 4 22,882,533. 25,426,777. 5 Owner's equity 5 43,792,224. 42,680,661. 6 Total liabilities and owner's equity 6 66,674,757. 68,107,438. Schedule G I Other Information 1 During the tax year, did the foreign disregarded entity own an interest in any trust? 2 During the tax year, did the foreign disregarded entity own at least a 10% interest, directly or indirectly, in any foreign partnership? 3 Answer the following question only if the foreign disregarded entity made its Section to be treated as disregarded from its owner during the tax year: Did the tax owner claim a loss with respect to stock or debt of the foreign disregarded entity as a result of the election? 4 If the interest in the foreign disregarded entity is a separate unit under Reg. 1.1503(d)-1(bX4) or part of a combined separate unit under reg. 1.1503(d)-1(bX4)(ii) does the separate unit or combined separate unit have a dual consoidated loss as defined in Reg. 1.1503(d)-1(b)(5)(10? If "Yes; enter the amount of the dual consolidated loss► $ Answer question 5a. Yes No X X N /A Form 8858 (Rev. 12-2013) 31,412 12-10.13 13061007 133415 T-1009 522 2013.04030 BLACK, LEON T-10094 EFTA01114678 LEON D. & DEBRA BLACK Form 8858 (Rev. 12-2013) Schedule G I Other Information (continued) Page 3 5a Was any portion of the dual consolidated loss in question 4 taken into account in computing consolidated taxable income for the year? If "Yes; go to 5b. 'No; skip 5b and 5c b Was this permitted domestic use of the dual consolidated loss under Reg. 1.1503(d)-6? If 'Yes, see instructions and skip 5c. It"No," go to 5c c If this was not a permitted domestic use, was the dual consolidated loss used to compute consolidated taxable income as provided under Reg. 1.503(d)-4? If "Yes; enter the separate unit's contribution to the cumulative consolidated Taxable income (cumulative register) as of the beginning of the lax year Ne. $ See Instructions. 6 During the tax year, did the foreign disregarded entity pay or accrue any foreign tax that was disqualified for credit under section 901(m)? 7 During the tax year, did the foreign disregarded entity pay or accrue foreign taxes to which section 909 applies, or treat foreign taxes that were previously suspended under section 909 as no longer suspended? 8 Answer the following question only if the tag owner of the foreign disregarded entity k a controlled foreign corporation (CFC): Were there any intracompany transactions between the foreign disregarded entity and the CFC or any other branch of the CFC during the tax year, in which the foreign disregarded entity acted as a manufacturing, selling, or purchasing branch? Current Earnings and Profits or Taxable Income (see instructions) Schedule H Important Enter the amounts on lines 7 through 6 in functional currency. I Current year net income or (loss) per foreign books of account 2 Total net additions 3 Total net subtractions 4 Current earnings and profits (or taxable income — see instructions) (Iine 1 plus ire 2 us line 3) 5 DASTM gain or loss (if applicable) 6 Combine lines 4 and 5 7 Current earnings and profits (or taxable income) in U.S. doNars eine 6 translated at the average exchange rate determined under section 989(b) and the related regulations (see instructions)) Enter exchange rate used for line 7 ► Yes No 40;71 2 3 4 5 6 7 Form 8858 (Rev. 12-2013) 31,413 V-10.13 523 13061007 133415 T-1009 2013.04030 BLACK, LEON T-10094 EFTA01114679 Form 8858 Information Return of U.S. Persons With Respect To Foreign Disregarded Entities lb. Information about Form 8858 and its separate instructions Is at vAvw.lrs.gov/form885& OMB No. 1545-1910 0a.ey. December 2013) Department of the Treasury Internal Revenue Service Name of person filing this return Flier's Identifying number LEON D. & DEBRA BLACK Information furnished for the foreign disregarded entitys annual accounting period (see instructions) Attachment beginning JAN 1 .2013 . and ending DEC 31 .20 13 $80taance No 140 x number it mail is not delivered to street address) Filer's tax year beginning JAN , 20 13 , and ending DEC 31 ,2013 Important Fill in all applicable lines and schedules. All information must be in English. All amounts must be stated in U.S. dollars unless otherwise indicated. la Name and address of foreign disregarded entity 6(1) U.S. identifying number, if any MARLYEBONE RETAIL LIMITED REGENTS WHARF, ALL SAINTS ST b(2) Reference ID number (see instructions) LONDON N1 9PA UNITED KINGDOM e Country(ies) under whose laws organized and entity type under local tax law UNITED KINGDOM CORPORATION d Date(s) of organization 10 03 12 e Effective date as foreign disregarded entity 10/03/12 I Functional currency If benefits under a U.S. tax treaty were claimed with respect to income of the foreign disregarded entity, enter the treaty and article number g Country in which principal business activity is conducted UNITED KINGDOM it Principal business activity RETAIL BOOKS UNITED KINGDOM, POUND 2 Provide the following information for the foreign disregarded entity's a counting period stated above. a Name, address, and identifying number of branch office or agent (if any) in the b NAT,. and adotwn Procuring corporato dapxtrnant. It applwab90 01 PerS0001 with mated/ United States 44 tne books are records of the tenser, oegegardeci entity. AM MA location 01 such books - amirecvos.uoe4gem ANDREW PRICE REGENTS WHARF, ALL SAINTS ST LONDON, N1 9PA UNITED KINGDOM 3 For the tax owner of the foreign disregarded entity (if different from the filer) provide the following: a Name and address b Annual accounting period covered by the return (see instructions) e(l) U.S. identifying number, if any e(2) Reference ID number (see instructio s) d Country under whose laws organized e Functional currency 4 For the direct owner of the foreign disregarded entity (if different from the tax owner provide the following: a Name and address PHAIDON PRESS LTD. ti Country under whose laws organized REGENTS WHARF, LONDON, N1 ALL 9PA SAINTS ST UNITED KINGDOM UNITED KINGDOM e U.S. identifying number, if any currency IJNFunctional ITED KINGDOM,PO 5 Attach an organizational chart that identities the name. placement percentage of ownership. tax dassilication. wadcountry of organization of all entities in Ihe chain of ownership between the tax ma and the foreign disregarded entity. and the cheil of ernership between the lorelgi disregarded entity end each entity In which the Sorelr disregarded entity Wise 1094 or more direct or ndieci nterest See. instructions. SEE STATEMENT 79 For Paperwork Reduction Act Notice, see the separate instructions. 1-07118858 (Rev. 12-2013) 512411 12-10.15 IHA 13061007 133415 T-1009 524 2013.04030 BLACK, LEON T-10094 EFTA01114680 LEON D. & DEBRA BLACK Form 8858 (Rev. 12-2013) Page 2 Schedule C I Income Statement (see instructions) Important Report all information in functional currency in accordance with U.S. GAAP. Also, report each amou—nitn U.S. dollars transla functional currency (using GAAP translation rules or the average exchange rate determined under section 989(b)). If the functional currency is the U.S. dollar. complete only the U.S. Dollars column. See instructions for special rules for foreign disregarded entities that use DASTM. If you are using the average exchange rate (determined under section 989(b)), check the following box Functional Currency U.S. Dollars 1 Gross receipts or sales (net of returns and allowances) 1 160,322. 2 Cost of goods sold 2 73,344. 3 Gross profit (subtract line 2 from line 1) 3 86,978. 4 Other income 4 5 Total income (add Ines 3 and 4) 5 86,978. 6 Total deductions 6 109,200. 7 Other adjustments 7 8 Net income (loss) per books 8 -22,222. 'Schedule C-1 I Section 987 Gain or Loss Information (a) (b) Note. See the instructions if there are multiple recipients of remittances from the foreign disregarded entity. Amount stated in functional currency of foreign disregarded entity Amount stated in functional currency of recipient 1 Remittances from the foreign disregarded entity 1 2 Section 987 gain (loss) of recipient 2 Yes No 3 Were all remittances from the foreign disregarded entity treated as made to the direct owner? 4 Did the tax owner change its method of accounting for section 987 gain or loss with respect to remittances from the foreign disregarded entity during the tax year? .. w Schedule F I Balance Sheet Important Report all amounts in U.S. dollars computed in functional currency and translated into U.S. dollars in accordance with U.S. GAAP. See instructions loran exception for foreign disregarded entities that use DASTM. 1 Cash and other current assets 2 Other assets e Liabilities and Ov:n filty %CO 3 Total assets 4 Liabilities 5 Owner's equity 6 Total liabilities and owner's equity Schedule G I Other Information Beginning of annual accounting period 1 6,572. 2 38,038. 3 44,610. 4 547,898. 5 -503,288. 6 44,610. End of annual accounting period 28,824. 32,871. 61,695. 599,168. —537,473. 61,695. 1 During the tax year, did the foreign disregarded entity own an interest in any trust? 2 During the tax year, did the foreign disregarded entity own at least a 10% interest, directly or indirectly, in any foreign partnership? 3 Answer the following question only if the foreign disregarded entity made its Section to be treated as disregarded from its owner during the tax year: Did the tax owner claim a loss with respect to stock or debt of the foreign disregarded entity as a result of the election? 4 If the interest in the foreign disregarded entity is a separate unit under Reg. 1.1503(d)-1(bX4) or part of a combined separate unit under reg. 1.1503(d)-1(bX4)(ii) does the separate unit or combined separate unit have a dual consoidated loss as defined in Reg. 1.1503(d)-1(b)(5)(10? If "Yes; enter the amount of the dual consolidated loss► $ Answer question 5a. Yes No X X N /A Form 8858 (Rev. 12-2013) 31,412 12-10.13 13061007 133415 T-1009 525 2013.04030 BLACK, LEON T-10094 EFTA01114681 LEON D. & DEBRA BLACK Form 8858 (Rev. 12-2013) Schedule G I Other Information (continued) Page 3 5a Was any portion of the dual consolidated loss in question 4 taken into account in computing consolidated taxable income for the year? If "Yes; go to 5b. 'No; skip 5b and 5c b Was this permitted domestic use of the dual consolidated loss under Reg. 1.1503(d)-6? If 'Yes, see instructions and skip 5c. It"No," go to 5c c If this was not a permitted domestic use, was the dual consolidated loss used to compute consolidated taxable income as provided under Reg. 1.503(d)-4? If "Yes; enter the separate unit's contribution to the cumulative consolidated Taxable income (cumulative register) as of the beginning of the lax year Ne. $ See Instructions. 6 During the tax year, did the foreign disregarded entity pay or accrue any foreign tax that was disqualified for credit under section 901(m)? 7 During the tax year, did the foreign disregarded entity pay or accrue foreign taxes to which section 909 applies, or treat foreign taxes that were previously suspended under section 909 as no longer suspended? 8 Answer the following question only if the tag owner of the foreign disregarded entity k a controlled foreign corporation (CFC): Were there any intracompany transactions between the foreign disregarded entity and the CFC or any other branch of the CFC during the tax year, in which the foreign disregarded entity acted as a manufacturing, selling, or purchasing branch? Current Earnings and Profits or Taxable Income (see instructions) Schedule H Important Enter the amounts on lines 7 through 6 in functional currency. I Current year net income or (loss) per foreign books of account 2 Total net additions 3 Total net subtractions 4 Current earnings and profits (or taxable income — see instructions) (Iine 1 plus ire 2 us line 3) 5 DASTM gain or loss (if applicable) 6 Combine lines 4 and 5 7 Current earnings and profits (or taxable income) in U.S. doNars eine 6 translated at the average exchange rate determined under section 989(b) and the related regulations (see instructions)) Enter exchange rate used for line 7 ► Yes No 40;71 2 3 4 5 6 7 Form 8858 (Rev. 12-2013) 31,413 V-10.13 526 13061007 133415 T-1009 2013.04030 BLACK, LEON T-10094 EFTA01114682 Form 8858► Information Return of U.S. Persons With Respect To Foreign Disregarded Entities Information about Form 8858 and its separate instructions Is at vAvw.Irs.gov/fortn885& OMB No. 1545-1910 BERLIN 12043 GERMANY e Country(ies) under whose laws organized and entity type under local tax law GERMANY CORPORATION geev.D 2013) Oepartment of the Tie...laity internal Revenue Service Name of person filing this return Filer's Identifying number LEON D. & DEBRA BLACK Information furnished for the foreign disregarded entitys annual accounting period (see instructions) Attechinent beginning JAN 1 ,m13 . and ending DEC 31 . Dacitaance No 140 2013 x number it mail is not delivered to street address) year egin , 20 1 3 ,and ending DEC 31 ,20 13 Important Fill in all applicable lines and schedules. All information must be in English. All amounts must be stated in U.S. dollars unless otherwise indicated. la Name and address of foreign disregarded entity 6(1) U.S. identifying number, if any PHAIDON VERLAG GMBH INNSTRA030 b(2) Reference ID number (see instructions) d Date(s) of organization 10 03 12 e Effective date as foreign disregarded entity 10/03/12 I Functional currency If benefits under a U.S. tax treaty were claimed with respect to income of the foreign disregarded entity, enter the treaty and article number g Country in which principal business activity is conducted GERMANY h Principal business activity PUBLISHING EUROPEAN UNION, EURO 2 Provide the following information for the foreign disregarded entity's a counting petdd stated above. a Name, address, and identifying number of branch office or agent (if any) in the b NAT,. and adotmc tincturing corporate depalmant. It appicatae) of P.S00(e) wen mated/ ot the books ar+i concede of Ihe forcer owegarded entity. AM the location of such boots United States awreopfus.iice4gem ANDREW PRICE REGENTS WHARF, ALL SAINTS ST LONDON, N1 9PA UNITED KINGDOM 3 For the tax owner of the foreign disregarded entity (if different from the filer) provide the following: a Name and address f?% b Annual accounting period covered by the return (see instructions) e(1) U.S. identifying number, if any e(2) Reference ID number (see instructio s) d Country under whose laws organized e Functional currency 4 For the direct owner of the foreign disregarded entity (if different from the tax owner provide the following: a Name and address PHAIDON PRESS LTD. b Country under whose laws organized REGENTS WHARF, LONDON, N1 ALL 9PA SAINTS ST UNITED KINGDOM UNITED KINGDOM e U.S. identifying number, if any currency 141Functional ITED KINGDOM,PO 5 Attach an orepnizational chart that identities the name. placement. percentage of ownership. tax classification. endcounty of orepnization of all entities in the chain of ownership between the tax onmer and the loreign disregarded entity. and the civil of ownership between the loreir disregarded entity end each entity In which the foreign disregarded entity has a 11)94 or more direct or ndieci nines,. See. instructions. SEE STATEMENT 80 For Paperwork Reduction Act Notice, see the separate instructions. Fain 8858 (Rev. 12-2013) 512411 12-10.15 IHA 13061007 133415 T-1009 527 2013.04030 BLACK, LEON T-10094 EFTA01114683 LEON D. & DEBRA BLACK Form 8858 (Rev. 12-2013) Page 2 Schedule C I Income Statement (see instructions) Important Report all information in functional currency in accordance with U.S. GAAP. Also, report each amou—nitn U.S. dollars transla functional currency (using GAAP translation rules or the average exchange rate determined under section 989(b)). If the functional currency is the U.S. dollar. complete only the U.S. Dollars column. See instructions for special rules for foreign disregarded entities that use DASTM. If you are using the average exchange rate (determined under section 989(b)), check the following box D6 1 Gross receipts or sales (net of returns and allowances) 2 Cost of goods sold 3 Gross profit (subtract line 2 from line 1) 4 Other income 5 Total income (add Ines 3 and 4) 6 Total deductions 7 Other adjustments 8 Net income (loss) per books Functional Currency U.S. Dollars 1 2 3 4 5 6 105,397. 7 8 -105,397. I-Schedule C-1 I Section 987 Gain or Loss Information (a) (b) Note. See the instructions if there are multiple recipients of remittances Amount stated in Amount stated in from the foreign disregarded entity. functional currency of functional currency foreign disregarded entity of recipient 1 Remittances from the foreign disregarded entity 1 2 Section 987 gain (loss) of recipient 2 Yes No 3 Were all remittances from the foreign disregarded entity treated as made to the direct owner? 4 Did the tax owner change its method of accounting for section 987 gain or loss with respect to remittances from the foreign disregarded entity during the tax year? .. Schedule F I Balance Sheet Important Report all amounts in U.S. dollars computed in functional currency and translated into U.S. dollars in accordance with U.S. GAAP. See instructions loran exception for foreign disregarded entities that use DASTM. 1 Cash and other current assets 2 Other assets e Liabilities and Ov:n filty %CO 3 Total assets 4 Liabilities 5 Owner's equity 6 Total liabilities and owner's equity Schedule G I Other Information Beginning of annual accounting period End of annual accounting period 1 2 3 5,0[5. 135,458. 456,389. 591,847. 399,621. 404,636. 4 5 6 877,925. 1,195,860. -473,289. -604,013. 404,636. 591,847. 1 During the tax year, did the foreign disregarded entity own an interest in any trust? 2 During the tax year, did the foreign disregarded entity own at least a 10% interest, directly or indirectly, in any foreign partnership? 3 Answer the following question only if the foreign disregarded entity made its Section to be treated as disregarded from its owner during the tax year: Did the tax owner claim a loss with respect to stock or debt of the foreign disregarded entity as a result of the election? 4 If the interest in the foreign disregarded entity is a separate unit under Reg. 1.1503(d)-1(bX4) or part of a combined separate unit under reg. 1.1503(d)-1(bX4)(ii) does the separate unit or combined separate unit have a dual consoidated loss as defined in Reg. 1.1503(d)-1(b)(5)(10? If "Yes; enter the amount of the dual consolidated loss► $ Answer question 5a. Yes No X X N /A Form 8858 (Rev. 12-2013) 31,412 12-10.13 13061007 133415 T-1009 528 2013.04030 BLACK, LEON T-10094 EFTA01114684 LEON D. & DEBRA BLACK Form 8858 (Rev. 12-2013) Schedule G I Other Information (continued) Page 3 5a Was any portion of the dual consolidated loss in question 4 taken into account in computing consolidated taxable income for the year? If "Yes; go to 5b. 'No; skip 5b and 5c b Was this permitted domestic use of the dual consolidated loss under Reg. 1.1503(d)-6? If 'Yes, see instructions and skip 5c. It"No," go to 5c c If this was not a permitted domestic use, was the dual consolidated loss used to compute consolidated taxable income as provided under Reg. 1.503(d)-4? If "Yes; enter the separate unit's contribution to the cumulative consolidated Taxable income (cumulative register) as of the beginning of the lax year Ne. $ See Instructions. 6 During the tax year, did the foreign disregarded entity pay or accrue any foreign tax that was disqualified for credit under section 901(m)? 7 During the tax year, did the foreign disregarded entity pay or accrue foreign taxes to which section 909 applies, or treat foreign taxes that were previously suspended under section 909 as no longer suspended? 8 Answer the following question only if the tag owner of the foreign disregarded entity k a controlled foreign corporation (CFC): Were there any intracompany transactions between the foreign disregarded entity and the CFC or any other branch of the CFC during the tax year, in which the foreign disregarded entity acted as a manufacturing, selling, or purchasing branch? Current Earnings and Profits or Taxable Income (see instructions) Schedule H Important Enter the amounts on lines 7 through 6 in functional currency. I Current year net income or (loss) per foreign books of account 2 Total net additions 3 Total net subtractions 4 Current earnings and profits (or taxable income — see instructions) (Iine 1 plus ire 2 us line 3) 5 DASTM gain or loss (if applicable) 6 Combine lines 4 and 5 7 Current earnings and profits (or taxable income) in U.S. doNars eine 6 translated at the average exchange rate determined under section 989(b) and the related regulations (see instructions)) Enter exchange rate used for line 7 ► Yes No 40;71 2 3 4 5 6 7 Form 8858 (Rev. 12-2013) 31,413 V-10.13 529 13061007 133415 T-1009 2013.04030 BLACK, LEON T-10094 EFTA01114685 Form 8858 Ow. December 2013) Clepartment of the Tit-awry Intanal Revenue Service Name of person filing this return Filer's Identifying number LEON D. & DEBRA BLACK Information Return of U.S. Persons With Respect To Foreign Disregarded Entities ► Information about Form 8858 and its separate instructions Is at vAvw.lrs.gov/form885& Information furnished for the foreign disregarded entitys annual accounting period (see instructions) bernninl JAN 1 2013 .andendin DEC 31 .2013OMB No. 1545-1910 Attachment Sequence No. 140 Number street. and room or suite no. box number it mail is not delivered to street address) Filer's tax year beginning JAN 1 20 13 , and ending DEC 31 , 20 13 Important Fill in all applicable lines and schedules. AD information must be in English. All amounts must be stated in U.S. dollars unless otherwise indicated. la Name and address of foreign disregarded entity PHAIDON PRESS LTD SARL VIALE BIANCA MARIE 23 MILAN ITALY e Country(ies) under whose laws organized and entity type under local tax law ITALY CORPORATION 20122 big U.S. identifying number, if any b(2) Reference ID number (see instructions) d Date(s) of organization 10 03 12 e Effective date as foreign disregarded entity 10/03/12 I Functional currency f If benefits under a U.S. tax treaty were claimed with respect to income of the foreign disregarded entity, enter the treaty and article number g Country in which principal business activity is conducted ITALY 2 Provide the following information for the foreign disregarded entity's a counting period stated above. a Name, address, and identifying number of branch office or agent (if any) in the United States h Principal business activity PUBLISHING .1k EUROPEAN UNION, EURO b NAT,. and arktm:11ncAkang CCAPCIAIG dap.atroont. It aogewbk0 0111.50001wIth 0.44100, 44 tne books are !cowls of the foremen oaregerded entity. AM the I0Cat1011 ol such books and records. it deerent ANDREW PRICE REGENTS WHARF, ALL SAINTS ST LONDON, Ni 9PA UNITED KINGDOM 3 For the tax owner of the foreign disregarded entity (if different from the filer) provide the following: a Name and address b Annual accounting period covered by the return (see instructions) c(1) U.S. identifying number, if any e(2) Reference ID number (see instructio s) d Country under whose laws organized e Functional currency 4 For the direct owner of the foreign disregarded entity (if different from the tax owner provide the following: a Name and address PHAIDON PRESS LTD. b Country under whose laws organized REGENTS WHARF, LONDON, Ni ALL 9PA SAINTS ST UNITED KINGDOM UNITED KINGDOM e U.S. identifying number, if any currency 141Functional ITED KINGDOM,PO 5 Attach en organizational chart that identities the name. placement percentageof ownership. tax classilication. and county of organization of all entities in the chain of ownership between the tax chmer and the foreign disregarded entity. and the chain of Garner shlp between the lorelr disregarded entity end each entity In which the40441r dieregatcled entity Ilea a 1094 or mote direct or ndieci interest. See instructions. SEE STATEMENT 81 For Paperwork Reduction Act Notice, see the separate instructions. Fern 8858 (Rev. 12-2013) 512411 12-10.15 IHA 530 13061007 133415 T-1009 2013.04030 BLACK, LEON T-10094 EFTA01114686 LEON D. & DEBRA BLACK Form 8858 (Rev. 12-2013) Page 2 ScheduleS4 Income Statement (see instructions) Important Repon a I information in functional currency in accordance with U.S. GAAP. Also, report each amou—nttn U.S. dollars transla functional currency (using GAAP translation rules or the average exchange rate determined under section 989(b)). If the functional currency is the U.S. dollar. complete only the U.S. Dollars column. See instructions for special rubs for foreign disregarded entities that use DASTM. If you are using the average exchange rate (determined under section 989(b)), check the following box D6 1 Gross receipts or sales (net of returns and allowances) 2 Cost of goods sold 3 Gross profit (subtract line 2 from line 1) 4 Other income 5 Total income (add Ines 3 and 4) 6 Total deductions 7 Other adjustments 8 Net income (loss) per books Functional Currency U.S. Dollars 1 2 3 4 5 6 15,041. 7 8 -15,041. I-Schedule C-1 I Section 987 Gain or Loss Information (a) (b) Note. See the instructions if there are multiple recipients of remittances Amount stated in Amount stated in from the foreign disregarded entity. functional currency of functional currency foreign disregarded entity of recipient 1 Remittances from the foreign disregarded entity 2 Section 987 gain (loss) of recipient 2 Yes No 3 Were all remittances from the foreign disregarded entity treated as made to the direct owner? 4 Did the tax owner change its method of accounting for section 987 gain or loss with respect to remittances from the foreign disregarded entity during the tax year? ... Schedule F I Balance Sheet Important Report all amounts in U.S. dollars computed in functional currency and translated into U.S. dollars in accordance with U.S. GAAP. See instructions loran exception for foreign disregarded entities that use DASTM. ( Assets ?lee Beginning of annual accounting period End of annual accounting period 1 Cash and other current assets 1 2 Other assets 2 421,910. 472,692. 3 Total assets 3 421,910. 472,692. Liabilities Car:nefifty % and 4 Liabilities 4 407,939. 472,914. 5 Owner's equity 5 13,971. -222. 6 Total liabilities and owner's equity 6 421,910. 472,692. Schedule G I Other Information 1 During the tax year, did the foreign disregarded entity own an interest in any trust? 2 During the tax year, did the foreign disregarded entity own at least a 10% interest, directly or indirectly, in any foreign partnership? 3 Answer the following question only if the foreign disregarded entity made its election to be treated as disregarded from Its owner during the tax year: Did the tax owner claim a loss with respect to stock or debt of the foreign disregarded entity as a result of the election? 4 If the interest in the foreign disregarded entity is a separate unit under Reg. 1.1503(d)-1(bX4) or part of a combined separate unit under reg. 1.1503(d)-1(bX4)(ii) does the separate unit or combined separate unit have a dual consoidated loss as defined in Reg. 1.1503(d)-1(b)(5)(9)? If "Yes; enter the amount of the dual consolidated loss► $ Answer question 5a. Form 8858 (Rev. 12-2013) Yes No X X N /A 31,412 12-10.13 531 13061007 133415 T-1009 2013.04030 BLACK, LEON T-10094 EFTA01114687 LEON D. & DEBRA BLACK Form 8858 (Rev. 12-2013) Schedule G I Other Information (continued) Page 3 5a Was any portion of the dual consolidated loss in question 4 taken into account in computing consolidated taxable income for the year? If "Yes; go to 5b. 'No; skip 5b and 5c b Was this permitted domestic use of the dual consolidated loss under Reg. 1.1503(d)-6? If 'Yes, see instructions and skip 5c. It"No," go to 5c c If this was not a permitted domestic use, was the dual consolidated loss used to compute consolidated taxable income as provided under Reg. 1.503(d)-4? If "Yes; enter the separate unit's contribution to the cumulative consolidated Taxable income (cumulative register) as of the beginning of the lax year Ne. $ See Instructions. 6 During the tax year, did the foreign disregarded entity pay or accrue any foreign tax that was disqualified for credit under section 901(m)? 7 During the tax year, did the foreign disregarded entity pay or accrue foreign taxes to which section 909 applies, or treat foreign taxes that were previously suspended under section 909 as no longer suspended? 8 Answer the following question only if the tag owner of the foreign disregarded entity k a controlled foreign corporation (CFC): Were there any intracompany transactions between the foreign disregarded entity and the CFC or any other branch of the CFC during the tax year, in which the foreign disregarded entity acted as a manufacturing, selling, or purchasing branch? Current Earnings and Profits or Taxable Income (see instructions) Schedule H Important Enter the amounts on lines 7 through 6 in functional currency. I Current year net income or (loss) per foreign books of account 2 Total net additions 3 Total net subtractions 4 Current earnings and profits (or taxable income — see instructions) (Iine 1 plus ire 2 us line 3) 5 DASTM gain or loss (if applicable) 6 Combine lines 4 and 5 7 Current earnings and profits (or taxable income) in U.S. doNars eine 6 translated at the average exchange rate determined under section 989(b) and the related regulations (see instructions)) Enter exchange rate used for line 7 ► Yes No 40;71 2 3 4 5 6 7 Form 8858 (Rev. 12-2013) 31,413 V-10.13 532 13061007 133415 T-1009 2013.04030 BLACK, LEON T-10094 EFTA01114688 Form 8858 Information Return of U.S. Persons With Respect To Foreign Disregarded Entities II. Information about Form 8858 and its separate instructions Is at vAvw.lrs.gov/form885& OMB No. 1545-1910 tRev. December 2013) IDepartment of the Treasury Internal Revenue Service Name of person filing this return LEON D. & DEBRA BLACK Information furnished for the foreign disregarded entitys annual accounting period (see instructions) Attechinent beginning JAN 1 .2013 . and ending DEC 31 .20 13 Sacitaance No 140 Filer's Identifying number tuber it mail is not delivered to street address) Filer's tax year beginning JAN , 20 13 , and ending DEC 31 ,2013 Important Fill in all applicable lines and schedules. AD information must be in English. All amounts must be stated in U.S. dollars unless otherwise indicated. la Name and address of foreign disregarded entity PHAIDON PRESS PTY LEVEL 19 2 MARKET STREE SYDNEY AUSTRALIA e Country(ies) under whose laws organized and entity type under local tax law AUSTRALIA CORPORATION NSW 200 b(I) U.S. identifying number, if any b(2) Reference ID number (see instructions) d Date(s) of organization 10 03 12 e Effective date as foreign disregarded entity 10/03/12 I Functional currency f If benefits under a U.S. tax treaty were claimed with respect to income of the foreign disregarded entity, enter the treaty and article number g Country in which principal business activity is conducted AUSTRIA b Principal business activity PUBLISHING AUSTRALIA, DOLLAR 2 Provide the following information for the foreign disregarded entity's a counting period stated above. a Name, address, and identifying number of branch office or agent (if any) in the b NAT,. and eactmo ilnduelng corporate dapdtrnent. It applicalsR0 of ParS0001 with O.44t0O, United States 44 tne books ard wards of the forams oedegarmaa entity. AM Ire location a such books and records. it orfrorent ANDREW PRICE REGENTS WHARF, ALL SAINTS ST LONDON, N1 9PA UNITED KINGDOM 3 For the tax owner of the foreign disregarded entity (if different from the filer) provide the following: a Name and address b Annual accounting period covered by the return (see instructions) e(1) U.S. identifying number, if any e(2) Reference ID number (see instructio s) d Country under whose laws organized e Functional currency 4 For the direct owner of the foreign disregarded entity (if different from the tax owner provide the following: a Name and address PHAIDON PRESS LTD. b Country under whose laws organized REGENTS WHARF, LONDON, N1 ALL 9PA SAINTS ST UNITED KINGDOM UNITED KINGDOM e U.S. identifying number, if any currency ILINFunctional ITED KINGDOM,PO 5 Attach en oregnizational chart that identities the name. placement. percentage of ownership. tax classification. endcountry of organization of all entities in the chain of ownership between Ihe tax cremw and the loreign disregarded entity. and the civil of ownership between the loreir disregarded entity end each entity In which the foreign disregarded entity has a 11)% or more direct or ndieci interest. See. instructions. SEE STATEMENT 82 For Paperwork Reduction Act Notice, see the separate instructions. Fern 8858 (Rev. 12-2013) 512411 12-10.15 IHA 13061007 133415 T-1009 533 2013.04030 BLACK, LEON T-10094 EFTA01114689 LEON D. & DEBRA BLACK Form 8858 (Rev. 12-2013) Page 2 lSchedule C [ Income Statement (see instructions) Important Report ail information in functional currency in accordance with U.S. GAAP. Also, report each amount in U.S. dollars translated from functional currency (using GAAP translation rules or the average exchange rate determined under section 989(b)). If the functional currency is the U.S. dollar. complete only the U.S. Dollars column. See instructions for special rules for foreign disregarded entities that use DAS TM. If you are using the average exchange rate (determined under section 989(b)), check the following box D6 Functional Currency U.S. Dollars 1 Gross receipts or sales (net of returns and allowances) 1 2 Cost of goods sold 2 3 Gross profit (subtract line 2 from line 1) 3 4 Other income 4 5 Total income (add Ines 3 and 4) 5 6 Total deductions 6 7 Other adjustments 7 8 Net income (loss) per books 8 Schedule C-1 I Section 987 Gain or Loss Information (a) (b) Note. See the instructions if there are multiple recipients of remittances from the foreign disregarded entity. Amount stated in functional currency of foreign disregarded entity Amount stated in functional currency of recipient 1 Remittances from the foreign disregarded entity 1 2 Section 987 gain (loss) of recipient 2 Yes No 3 Were all remittances from the foreign disregarded entity treated as made to the direct owner? 4 Did the tax owner change its method of accounting for section 987 gain or loss with respect to remittances from the gweign disregarded entity during the tax year? Schedule F I Balance Sheet Important Report all amounts kt U.S. dollars computed in functional currency and translated into U S. dollars in accords See instructions for an exception for foreign disregarded entities that use DASTM. with U.S. GAAP. Assets 1 Cash and other current assets 2 Other assets 3 Total assets 4 Liabilities 5 Owner's equity 6 Total liabilities and ovm