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held by the Issuer in respect of such lease or other transaction is treated as debt for U.S. federal income tax purposes and (d) it has a rating by Moody's and S&P. "Financial Asset": The meaning specified in Article 8 of the UCC. "Financing Statement": The meaning specified in Article 9 of the Uniform
derived from assets located, in Recovery Approved Countries but that is incorporated or formed, as applicable, in any Tax Jurisdiction. "Excepted Property": $500 (comprised of $250 received in connection with the issuance of the ordinary shares of the Issuer and $250 received as a
held by the Issuer in respect of such lease or other transaction is treated as debt for U.S. federal income tax purposes and (d) it has a rating by Moody's and S&P. "Fiscal Agency Agreement": The Fiscal Agency Agreement dated as of the Closing Date among the Fiscal Agent. the Share Registrar and the Is
and a majority of its revenue derived from assets located, in Recovery Approved Countries but that is incorporated or formed. as applicable, in any Tax Jurisdiction. "Excess Interest": Any Interest Proceeds distributed on the Subordinated Securities pursuant to the Priority of Interest Proceeds. "FATCA Complia
held by the Issuer in respect of such lease or other transaction is treated as debt for U.S. federal income tax purposes and (d) it has a rating by Moody's and S&P. "Financial Asset": The meaning specified in Article 8 of the UCC. "Financing Statement": The meaning specified in Article 9 of the Uniform
derived from assets located, in Recovery Approved Countries but that is incorporated or formed, as applicable, in any Tax Jurisdiction. "Excepted Property": $500 (comprised of $250 received in connection with the issuance of the ordinary shares of the Issuer and $250 received as a
Entities connected to both Moody's and Tax Jurisdiction

the Cayman Islands
LOCATIONFATCA Compliance
ORGANIZATIONThe United States Securities Exchange Act
LOCATIONthe Priority of Interest Proceeds
ORGANIZATIONthe Preferred Shares Payment Account
ORGANIZATION