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reated as "attributable" to withholdable payments. The United Kingdom and the United States have entered into a Model 1 intergovernmental agreement (the "U.S. IGA') relating to FATCA and the United Kingdom has brought into law regulations to implement the provisions of the U.S. IGA (such regulations and any fu
ndirectly hold an interest in the Fund through a non-U.S. Investor. HMRC will provide this information to the IRS. So long as the Fund complies with the UK FATCA Legislation, FATCA withholding generally will not be imposed on payments made to the Fund, or on an Investor's share (whether or not distributed) of such payments, exc
reated as "attributable" to withholdable payments. The United Kingdom and the United States have entered into a Model 1 intergovernmental agreement (the "U.S. IGA') relating to FATCA and the United Kingdom has brought into law regulations to implement the provisions of the U.S. IGA (such regulations and any fu
ndirectly hold an interest in the Fund through a non-U.S. Investor. HMRC will provide this information to the IRS. So long as the Fund complies with the UK FATCA Legislation, FATCA withholding generally will not be imposed on payments made to the Fund, or on an Investor's share (whether or not distributed) of such payments, exc
treated as "attributable to withholdable payments. The United Kingdom and the United States have entered into a Model 1 intergovernmental agreement (the "U.S. IGA') relating to FATCA and the United Kingdom has brought into law regulations to implement the provisions of the U.S. IGA (such regulations and any fu
ndirectly hold an interest in the Fund through a non-U.S. Investor. HMRC will provide this information to the IRS. So long as the Fund complies with the UK FATCA Legislation, FATCA withholding generally will not be imposed on payments made to the Fund, or on an Investor's share (whether or not distributed) of such payments, exc
reated as "attributable" to withholdable payments. The United Kingdom and the United States have entered into a Model 1 intergovernmental agreement (the "U.S. IGA') relating to FATCA and the United Kingdom has brought into law regulations to implement the provisions of the U.S. IGA (such regulations and any fu
ndirectly hold an interest in the Fund through a non-U.S. Investor. HMRC will provide this information to the IRS. So long as the Fund complies with the UK FATCA Legislation, FATCA withholding generally will not be imposed on payments made to the Fund, or on an Investor's share (whether or not distributed) of such payments, exc
treated as -attributable to withholdable payments. The United Kingdom and the United States have entered into a Model 1 intergovernmental agreement (the "U.S. IGA') relating to FATCA and the United Kingdom has brought into law regulations to implement the provisions of the U.S. IGA (such regulations and any fu
ndirectly hold an interest in the Fund through a non-U.S. Investor. HMRC will provide this information to the IRS. So long as the Fund complies with the UK FATCA Legislation, FATCA withholding generally will not be imposed on payments made to the Fund, or on an Investor's share (whether or not distributed) of such payments, exc
reated as "attributable" to withholdable payments. The United Kingdom and the United States have entered into a Model 1 intergovernmental agreement (the "U.S. IGA') relating to FATCA and the United Kingdom has brought into law regulations to implement the provisions of the U.S. IGA (such regulations and any fu
ndirectly hold an interest in the Fund through a non-U.S. Investor. HMRC will provide this information to the IRS. So long as the Fund complies with the UK FATCA Legislation, FATCA withholding generally will not be imposed on payments made to the Fund, or on an Investor's share (whether or not distributed) of such payments, exc
Entities connected to both the "U.S. IGA' and the UK FATCA Legislation, FATCA