rtner's interest in the Fund generally will be limited to withholding tax on certain gross income from U.S. sources generated by the Fund as long as the Non-U.S. Partner undertakes no activities in the United States (determined without regard to its investment in the Fund) that would cause that Non-U.S. Part

rtner claims to be entitled to a reduced rate of, or exemption from, U.S withholding tax pursuant to an applicable income tax treaty, or otherwise, the Non-U.S. Partner shall furnish the General Partner with such information and forms as they may require and are necessary to comply with the regulations gove