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ONLY AND MAY NOT BE APPLICABLE DEPENDING UPON A HOLDER'S PARTICULAR SITUATION. PROSPECTIVE PURCHASERS OF
formation, information relating to the amount of interest paid and the amount of backup withholding, if any, with respect to payments on the Notes. Non-U.S. Holders The following summary is limited to the U.S. federal income tax consequences relevant to a beneficial owner of a Note (other than a partnership or
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States federal income tax purposes.. or • a U.S. Holder whose " functional currency" is not the United St
on, the entire amount received will be treated as a distribution and will be taxable as described under the caption " aaxation of Dividends" above. Non-U.S. Holders The following discussion is a summary of certain United States federal tax consequences that will apply to you if you are a non-U.S. Holder of depo
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le income" ("UBIT). If an Investor is a Non-U.S. Holder (as defined below) for U.S. tax purposes, that I
the Onshore Feeder Fund since adverse tax consequences could result for the Investor. Accordingly, the Onshore Feeder Fund is not being offered to Non-U.S. Holders. U.S. tax-exempt Investors that are not willing to receive material amounts of UBTI and Non-U.S. Holders should, if eligible, instead consider an
Sponsored
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Interests. For purposes of this summary, a "U.S. Holder" is a beneficial owner of an interest in the Ons
e Feeder Fund by U.S. Holders (as defined herein) and of Interests in the Offshore Feeder Fund by U.S. Tax-Exempt Investors (as defined herein) and Non-U.S. Holders (as defined herein) who purchase their respective interests in the offering. This summary is based upon the Code, U.S. Department of the Treasury (
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Interests. For purposes of this summary, a "U.S. Holder" is a beneficial owner of an interest in the Ons
e Feeder Fund by U.S. Holders (as defined herein) and of Interests in the Offshore Feeder Fund by U.S. Tax-Exempt Investors (as defined herein) and Non-U.S. Holders (as defined herein) who purchase their respective interests in the offering. This summary is based upon the Code, U.S. Department of the Treasury (
Sponsored
Mutual Connections (11)
Entities connected to both Eric Holder and Non-U.S. Holders
United States
LOCATION201 w/ Eric·2 w/ Non-U.S.
JPMorgan Chase
ORGANIZATION58 w/ Eric·2 w/ Non-U.S.
the Internal Revenue Service
ORGANIZATION46 w/ Eric·4 w/ Non-U.S.
the Securities and Exchange Commission
ORGANIZATION29 w/ Eric·3 w/ Non-U.S.
U.S. Treasury
ORGANIZATION22 w/ Eric·3 w/ Non-U.S.
United Kingdom
LOCATION23 w/ Eric·2 w/ Non-U.S.
U.S. Department
ORGANIZATION14 w/ Eric·2 w/ Non-U.S.
the New York Banking Law
ORGANIZATION4 w/ Eric·2 w/ Non-U.S.
Regulation M
ORGANIZATION2 w/ Eric·2 w/ Non-U.S.
The Onshore Feeder Fund's
ORGANIZATION2 w/ Eric·2 w/ Non-U.S.
Offshore Feeder Fund
ORGANIZATION2 w/ Eric·2 w/ Non-U.S.