Epstein Secrets

ity interests in the Issuer for U.S. federal income tax purposes. The Subordinated Notes will be characterized as debt of the Issuer for purposes of Cayman Islands law. However, a strong likelihood exists that the Subordinated Notes will be treated as equity of the Issuer for U.S. federal income tax purposes.

OID. Further information regarding OID may be obtained by contacting the Issuer at its registered office as described under "Issuer and Co-Issuer." Tax Treatment of US. Holders of Subordinated Securities The Preferred Shares will be treated as equity interests in the Issuer for U.S. federal income tax purposes. Th

With respect to Cayman Islands taxation, see the discussion below in "— Cayman Islands Tax Considerations." Withholding and Gross Income Taxes. Although the Issuer does not intend

es. Issuance of Notes. For U.S. federal income tax purposes, the Issuer, and not the Co-Issuer, will be treated as the issuer of the Senior Notes. Tax Treatment of US. Holders of Rated Notes Status of and Interest on, the Class A Notes The Class A Notes will be treated as debt for U.S. federal income tax purposes

ity interests in the Issuer for U.S. federal income tax purposes. The Subordinated Notes will be characterized as debt of the Issuer for purposes of Cayman Islands law. However, a strong likelihood exists that the Subordinated Notes will be treated as equity of the Issuer for U.S. federal income tax purposes.

OID. Further information regarding OID may be obtained by contacting the Issuer at its registered office as described under "Issuer and Co-Issuer." Tax Treatment of US. Holders of Subordinated Securities The Preferred Shares will be treated as equity interests in the Issuer for U.S. federal income tax purposes. Th