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nefit plan subject to the fiduciary provisions of Title I of ERISA with total assets of less than $50 million or an individual retirement account, Keogh plan and/or other plan subject to Section 4975 of the Code that is not subject to the fiduciary provisions of ERISA (or if the Investor is an ent
s interests in the Partnership, and (z) permitting the Partnership to satisfy the 100-partner limitation set forth in Section 1.7704-1(h)(1)(ii) of the U.S. Treasury Regulations is not a principal purpose of any beneficial owner of the Sole Owner, or of any person authorized to act on the Sole Owner's behalf, for using the
nefit plan subject to the fiduciary provisions of Title I of ERISA with total assets of less than $50 million or an individual retirement account, Keogh plan and/or other plan subject to Section 4975 of the Code that is not subject to the fiduciary provisions of ERISA (or if the Investor is an ent
s interests in the Partnership, and (z) permitting the Partnership to satisfy the 100-partner limitation set forth in Section 1.7704-1(h)(1)(ii) of the U.S. Treasury Regulations is not a principal purpose of any beneficial owner of the Sole Owner, or of any person authorized to act on the Sole Owner's behalf, for using the
nefit plan subject to the fiduciary provisions of Title I of ERISA with total assets of less than $50 million or an individual retirement account, Keogh plan and/or other plan subject to Section 4975 of the Code that is not subject to the fiduciary provisions of ERISA (or if the Investor is an ent
s interests in the Partnership, and (z) permitting the Partnership to satisfy the 100-partner limitation set forth in Section 1.7704-1(h)(1)(ii) of the U.S. Treasury Regulations is not a principal purpose of any beneficial owner of the Sole Owner, or of any person authorized to act on the Sole Owner's behalf, for using the
Entities connected to both Keogh and the U.S. Treasury Regulations

United States
LOCATION
Marla Maples
PERSON
Cayman Islands
LOCATIONCalder
ORGANIZATIONiCapital
ORGANIZATION
Department of Labor
ORGANIZATIONSubchapter S
ORGANIZATION
United Kingdom
LOCATION
U.S. Treasury
ORGANIZATIONCleary Gottlieb
ORGANIZATION
Samantha Power
PERSONthe State of New York
LOCATIONthe District of Columbia
LOCATIONGlendower Capital
ORGANIZATIONGlendower
LOCATION
Joi Ito
PERSONU.S. Internal Revenue Service
ORGANIZATIONCleary Gottlieb Steen & Hamilton LLP
ORGANIZATIONThe Placement Fee
ORGANIZATIONiCapital Advisors
ORGANIZATION