use the Issuer to be treated as engaged in a trade or business within the United States. Any such departures would not be covered by the opinion of Cleary• Gottlieb Steen & Hamilton LLP referred to above. If the Issuer were engaged in a trade or business in the United States, it would potentially be subject to substantial U.S. feder

use the Issuer to be treated as engaged in a trade or business within the United States. Any such departures would not be covered by the opinion of Cleary• Gottlieb Steen & Hamilton LLP referred to above. If the Issuer were engaged in a trade or business in the United States, it would potentially be subject to substantial U.S. feder