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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.
held such Rated Note for more than one year at the time of disposition. In certain circumstances. U.S. holders that are individuals may be entitled to preferential treat
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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
n setting interest for that subsequent Interest Period and the assumed rate. Sale and Retirement of the Rated Notes. In general, a U.S. holder of a Rated Note will have a basis in such Rated Note equal to the cost of such Rated Note to such holder, increased by any amount includible in income by such hold
2 mentions1 same-page
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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.
held such Rated Note for more than one year at the time of disposition. In certain circumstances. U.S. holders that are individuals may be entitled to preferential treat
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Entities connected to both Cayman Islands and Rated Note
