Epstein Secrets

THE PARTICULAR CIRCUMSTANCES OF EACH PROSPECTIVE HOLDER AND, IN REVIEWING THIS OFFERING CIRCULAR, THESE

urged to consult their own tax advisors regarding the tax consequences of an investment in Class A shares. Passive Foreign Investment Companies and Controlled Foreign Corporations. It is possible that we will invest in non-U.S. corporations treated as PFICs or CFCs. A PFIC is defined as any foreign corporation with respect to

N FEDERAL INCOME TAX CONSIDERATIONS RELEVANT TO A HOLDER OF THE UNITS RESIDENT IN CANADA FOR PURPOSES OF T

their respective local tax jurisdictions, or (if) a deduction against income taxable in the U.S. or such local jurisdictions by the Investors. 6.2.4 Controlled Foreign Corporations KUE anticipates that it and/or its subsidiaries will invest in non-U.S. operations. Depending upon the percentage of ownership of such operations by

AS A CONDITION PRECEDENT TO ANY TRANSFER OF ANY SVC, THE INITIAL PURCHASER (AND ANY SUBSEQUENT HOLDER) SHALL REQUIRE THAT ANY SUBSEQUENT PURCHASER, HOLDER, OR TRANSFEREE OF SUCH SVC COVENANT NOT TO OFFER, SELL, RESELL, OR OTHERWISE TRANSFER SUCH SVCS TO ANY U.S. PERSON WHO IS NOT A QP AND TO FULLY COM

ns, including investments in "controlled foreign corporations" ("CFCs") and "passive foreign investment companies" ("PFICs"), both described below. Controlled Foreign Corporations. If a U.S. person owns, directly, indirectly or constructively, 10% or more of the combined voting power or value of the stock of a foreign corporat