Epstein Secrets

e United States, (2) a corporation, or entity treated as a corporation, organized in or under the laws of the United States or any state thereof or the District of Columbia, (3) a trust that (i) is subject to (a) the primary supervision of a court within the United States and (b) the authority of one or more U.S. person

"Excess Distribution" (as defined below) received in respect of Series A Preference Shares as if such items had been earned ratably over each day in the U.S. Holder's holding period (or a portion thereof) for the Series A Preference Shares. The amounts allocated to the taxable year during which the gain is realize

n entity treated as a corporation for U.S. federal income tax purposes, created or organized under the laws of die United States, or of any state or the District of Columbia: (c) an estate, the income of which is subject to U.S. federal income tax regardless of its source: or (d) a trust. if (i) a court within the United

ween the amount of cash received (determined before the deduction, if any, of any withholding tax) in exchange for Shares pursuant to the Offer and the U.S. Holder's adjusted tax basis in such Shares. Any such gain or loss will be long-term capital gain or loss if a U.S. Holder's holding period for such Shares is

n entity treated as a corporation for U.S. federal income tax purposes, created or organized under the laws of die United States, or of any state or the District of Columbia: (c) an estate, the income of which is subject to U.S. federal income tax regardless of its source: or (d) a trust. if (i) a court within the United

ween the amount of cash received (determined before the deduction, if any, of any withholding tax) in exchange for Shares pursuant to the Offer and the U.S. Holder's adjusted tax basis in such Shares. Any such gain or loss will be long-term capital gain or loss if a U.S. Holder's holding period for such Shares is

n entity treated as a corporation for U.S. federal income tax purposes, created or organized under the laws of die United States, or of any state or the District of Columbia: (c) an estate, the income of which is subject to U.S. federal income tax regardless of its source: or (d) a trust. if (i) a court within the United

ween the amount of cash received (determined before the deduction, if any, of any withholding tax) in exchange for Shares pursuant to the Offer and the U.S. Holder's adjusted tax basis in such Shares. Any such gain or loss will be long-term capital gain or loss if a U.S. Holder's holding period for such Shares is