be permitted under any circumstances whatsoever if such transfer and/or substitution would, or could, (i) jeopardize the limited liability emus of the Company for Federal income tax purposes or otherwise under United States Virgin Islands law; or (ii) cause a termination of the Company within the meaning of Section 7

e permitted under any circumstances whatsoever if such transfer and/or substitution would, or could, (i) jeopardize the limited liability status of the Company for Federal income tax purposes or otherwise under United States Virgin Islands law; or (ii) cause a termination of the Company within the meaning of Section 7

k USI:9600195v9 EFTA00587604 Regulations promulgated thereunder so as to take account of any difference between the tax basis of such property to the Company for Federal income tax purposes and its book basis. 4.1.3 If any Membership Interest is transferred or any Percentage Interest is changed pursuant to the terms