6
Shared Docs
6
Same-Page
6 / 6
Mentions
rson who becomes a successor to the Manager. "Master Fund" means Honeycomb Master Fund LP, an exempted limited partnership formed under the laws of the Cayman Islands. "Net Assets" means the excess of the Fund's assets over its liabilities. "Net Cash Flow" means, with respect to each Investment and any applicable
The Fund shall maintain a separate Capital Account for each Partner pursuant to the principles of Section 704(b) and Section 704(c) of the Code and the Treasury Regulations promulgated thereunder. Each Capital Account shall be credited or debited by the amounts allocated to such Capital Account under Section 5.08. The
rson who becomes a successor to the Manager. "Master Fund" means Honeycomb Master Fund LP, an exempted limited partnership formed under the laws of the Cayman Islands. "Net Assets" means the excess of the Fund's assets over its liabilities. "Net Cash Flow" means, with respect to each Investment and any applicable
The Fund shall maintain a separate Capital Account for each Partner pursuant to the principles of Section 704(b) and Section 704(c) of the Code and the Treasury Regulations promulgated thereunder. Each Capital Account shall be credited or debited by the amounts allocated to such Capital Account under Section 5.08. The
rson who becomes a successor to the Manager. "Master Fund" means Honeycomb Master Fund LP, an exempted limited partnership formed under the laws of the Cayman Islands. "Net Assets" means the excess of the Fund's assets over its liabilities. "Net Cash Flow" means, with respect to each Investment and any applicable
The Fund shall maintain a separate Capital Account for each Partner pursuant to the principles of Section 704(b) and Section 704(c) of the Code and the Treasury Regulations promulgated thereunder. Each Capital Account shall be credited or debited by the amounts allocated to such Capital Account under Section 5.08. The
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 Organization of Economic Coope
ppropriate documentation (generally an IRS Form W-8EC1). Additional Withholding Requirements Pursuant to Sections 1471 through 1472 of the Code and the Treasury Regulations promulgated thereunder ("FATCA"), we may be required to withhold U.S. tax at the rate of 30% on payments of interest and, beginning on January I, 2
of Delaware, and any successor thereto. "AMH Holdings" means AMH Holdings (Cayman), L.P., an exempted limited partnership formed under the laws of the Cayman Islands, and any successor thereto. "AOG Unit" shall have the meaning given to the term "Operating Group Unit" in the Shareholders Agreement. "APO Corp."
port any A Exchange consummated hereunder, as a tax-free contribution of AOG Units pursuant to Section 721 of the Code. As required by the Code and the Treasury Regulations, the parties shall report (a) any B Exchange consummated hereunder as a taxable sale to APO Corp. and APO FC, as applicable, of AOG Units by an Apol
l of the Members that the AlphaKeys Fund be re-structured as a Cayman Islands exempted limited partnership or other entity formed under the laws of the Cayman Islands (any such entity, a "Cayman Vehicle") the Member Designee may take and/or cause the Members to take all actions necessary and desirable to implemen
ry income. Furthermore, a 3.8% Medicare contribution tax will be imposed on the "net investment income" (as defined in Section 1411 of the Code and the Treasury Regulations thereunder) of individuals whose income exceeds certain threshold amounts and of certain trusts and estates under similar rules. Investors are advis
Entities connected to both the Cayman Islands and the Treasury Regulations
Cayman
LOCATION
United States
LOCATION
United Kingdom
LOCATION
Prince Andrew
PERSONLeon Black
PERSON
New York
LOCATION
George W. Bush
PERSON
Samantha Power
PERSONthe U.S. Investment Company Act
ORGANIZATION
the Internal Revenue Service
ORGANIZATIONReliance
ORGANIZATIONthe Southern District
LOCATION
Ghislaine Maxwell
PERSONthe Carried Interest
ORGANIZATIONthe Master Fund
ORGANIZATIONErnst & Young LLP
ORGANIZATIONthe New York Stock Exchange
ORGANIZATIONthe Delaware
ORGANIZATION
U.S. Treasury
ORGANIZATIONthe District of Columbia
LOCATION