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EFTA01370123
from less than 100% of the Preferred Shares that would be materially and adversely affected by any amendment to the Issuer's transaction documents. U.S. Federal Income Tax Treatment as Equity The Issuer intends to treat the Senior Notes as debt, and the Preferred Shares as equity, for U.S. federal income tax purposes. However, no ruling h
EFTA01370456
from less than 100% of the Preferred Shares that would be materially and adversely affected by any amendment to the Issuer's transaction documents. U.S. Federal Income Tax Treatment as Equity The Issuer intends to treat the Senior Notes as debt, and the Preferred Shares as equity, for U.S. federal income tax purposes. However, no ruling h

Eric Holder
PersonUnited States Attorney General from 2009 to 2015

the Cayman Islands
LocationBritish Overseas Territory in the Caribbean

the Internal Revenue Service
OrganizationInternal Revenue Service (IRS), US government agency responsible for tax collection and enforcement
Deutsche Asset Management Infrastructure Debt Presentation: RIN II Equity
OrganizationOrganization referenced in documents
Interest Accrual Period
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U.S. Withholding Tax and Compliance Risks under FATCA
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Non-Permitted Holder of Preferred
OrganizationOrganization referenced in documents