is, or is deemed to be, engaged in a trade or business in the United States. With respect to Cayman Islands taxation see the discussion below in "—Cayman Islands Tax Considerations." Withholding Taxes. Although the Issuer does not intend to be subject to U.S. federal income tax with respect to its net income, inc

is, or is deemed to be, engaged in a trade or business in the United States. With respect to Cayman Islands taxation see the discussion below in "—Cayman Islands Tax Considerations." Withholding Taxes. Although the Issuer does not intend to be subject to U.S. federal income tax with respect to its net income, inc