. federal income tax consequences of an investment in the Notes, including possible alternative treatments and the issues presented by this notice. Non-U.S. Holders. Insofar as we have responsibility as a withholding agent, we do not currently intend to treat Contingent Coupon payments to non-U.S. holders (as de

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

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

refund or a credit against a U.S. holder's U.S. federal income tax liability provided the required information is timely furnished to the IRS. 136 Non-U.S. Holders This section applies to you if you are a "Non-U.S. holder." A Non-U.S. holder is a beneficial owner of our units, shares of common stock and warran

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

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 (

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 (