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nd exclusively for the purpose of the offering. Therefore, it may not be used for any other purpose, nor passed on to any other person in Belgium. Bermuda Notice to Investors in Bermuda Interests in the Fund may not be marketed, offered or sold directly or indirectly to the public in Bermuda and neit
of the offering. Therefore, it may not be used for any other purpose, nor passed on to any other person in Belgium. Bermuda Notice to Investors in Bermuda Interests in the Fund may not be marketed, offered or sold directly or indirectly to the public in Bermuda and neither this Memorandum, which is no
hat, although the Partnership intends to adopt positions it believes are in accord with current interpretations of the U.S. federal income tax laws, the Internal Revenue Service ("IRS") may not agree with the tax positions taken by the Partnership and that, if challenged by the IRS, the Partnership's tax positions might not
t-spots-like-bermuda-are-offering-remote- work-visas-11598551270> (8/27, Kamin, Subscription Publication, 7.57M) reports that tourist hot spots like Bermuda and Barbados are offering visas to remote workers that allow them to work tax-free in the nation. According to the Journal, areas that rely heavily
s as part of a scheme to enable ATM withdrawals." The investigation into the "cryptocurrency accounts also involved the FBI, U.S. Cyber Command and the Internal Revenue Service (IRS)." The Wall Street Journal <https://www.wsj.corn/articles/u-s-moves-to-seize-cryptocurrency-accounts-linked-to- EFTA00136584 north-korean-hei
r other taxing authority other than a stamp, registration, documentation or similar tax. "Tax Advantaged Jurisdiction": One of the Cayman Islands, Bermuda, the Netherlands Antilles or the tax advantaged jurisdiction of the Channel Islands, or such other jurisdiction that each Rating Agency has confirm
e not required to make gross-up payments that cover the full amount of such withholding taxes on an after-tax basis or (ii) a final determination by the Internal Revenue Service or a court of competent jurisdiction or an opinion of nationally recognized tax counsel experienced in such matters acceptable to the Collateral Ma
of ( I) above, such Person is organized and existing under the laws of the United States of America, any state thereof or the District of Columbia, Bermuda, the Cayman Islands, Ireland, Switzerland, the United Kingdom or any other country which is on the date of the indenture a member of the Organizati
date of the debentures, the debentures will be treated as indebtedness for U.S. federal income tax purposes. However, there can be no assurance that the Internal Revenue Service ("IRS") or a court will agree with our determination. No ruling is being sought from the IRS on any of the issues discussed herein. S-24 EFTA_R1_0
r other taxing authority other than a stamp, registration, documentation or similar tax. "Tax Advantaged Jurisdiction": One of the Cayman Islands, Bermuda, the Netherlands Antilles or the tax advantaged jurisdiction of the Channel Islands, or such other jurisdiction that each Rating Agency has confirm
e not required to make gross-up payments that cover the full amount of such withholding taxes on an after-tax basis or (ii) a final determination by the Internal Revenue Service or a court of competent jurisdiction or an opinion of nationally recognized tax counsel experienced in such matters acceptable to the Collateral Ma
et Management LLC. an investment manager that provides asset management services to Athene Holding Ltd (together with its subsidiaries. "Athene"). a Bermuda holding 17 EFTA00623409 Table of Contents company founded in 2009 to capitalize on favorable market conditions in the dislocated life insurance
xempted limited partnership through which our managing partners and contributing partners hold their Apollo Operating Group units: ' IRS" refers to the Internal Revenue Service; "managing partners" refers to Messrs. Leon Black. Joshua Harris and Marc Rowan collectively and. when used in reference to holdings of interests in
r other taxing authority other than a stamp, registration, documentation or similar tax. "Tax Advantaged Jurisdiction": One of the Cayman Islands, Bermuda, the Netherlands Antilles or the tax advantaged jurisdiction of the Channel Islands, or such other jurisdiction that each Rating Agency has confirm
e not required to make gross-up payments that cover the full amount of such withholding taxes on an after-tax basis or (ii) a final determination by the Internal Revenue Service or a court of competent jurisdiction or an opinion of nationally recognized tax counsel experienced in such matters acceptable to the Collateral Ma
public attention — and denunciation from Congress and labor unions — in recent years.The much-publicized case involving the move of Stanley Works to Bermuda from Connecticut involved the company's official headquarters actually leaving the United States. But the U.S. Virgin Islands are part of the United
in's Chicago Business places him on its list of "Who's Who of Chicago Executives." But when tax time comes around and Mr. Driehaus has to file with the Internal Revenue Service, the address he lists isn't in Chicago; it's in St. Thomas, on the U.S.Virgin Islands, according to the foundation's federal tax return and a Virgi
Entities connected to both Bermuda and the Internal Revenue Service

Jeffrey Epstein
PERSON
JPMorgan Chase
ORGANIZATION
Newark
LOCATION
Ghislaine Maxwell
PERSON
Nassau
LOCATIONthe State of New York
LOCATION
United States
LOCATION
Federal Reserve
ORGANIZATIONLeon Black
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Justin Trudeau
PERSON
Bank of America
ORGANIZATION
Donald Trump
PERSON
Alan Dershowitz
PERSON
Julie K. Brown
PERSONMaria Farmer
PERSON
Samantha Power
PERSON
Financial Trust Company
ORGANIZATION
Department of Justice
ORGANIZATION