ns, including investments in "controlled foreign corporations" ("CFCs") and "passive foreign investment companies" ("PFICs"), both described below. Controlled Foreign Corporations. If a U.S. person owns, directly, indirectly or constructively, 10% or more of the combined voting power or value of the stock of a foreign corporat

GLDUS238 SOUTHERN FINANCIAL LLC Controlled Foreign Corporations. Special rules apply to U.S. persons who own, directly or indirectly and applying certain attribution rules, 10% or more of the total combined votin

GLDUS238 SOUTHERN FINANCIAL LLC Controlled Foreign Corporations. Special rules apply to U.S. persons who own, directly or indirectly and applying certain attribution rules, 10% or more of the total combined votin

GLOUS144 Glenn Warren Controlled Foreign Corporations. Special rules apply to U.S. persons who own, directly or indirectly and applying certain attribution rules, 10% or more of the total combined votin

GLDUS137 Forrestal Capital LLC Controlled Foreign Corporations. Special rules apply to U.S. persons who own, directly or indirectly and applying certain attribution rules, 10% or more of the total combined votin

g investments in "controlled %reign corporations" ("CFCs") and "passive foreign investment companies" ("PFICs"), both described immediately below. Controlled Foreign Corporations. If a U.S. Person, including any U.S. Limited Partner owns actually or constructively at least 10% of the voting stock of a non-U.S. corporation, su

their respective local tax jurisdictions, or (if) a deduction against income taxable in the U.S. or such local jurisdictions by the Investors. 6.2.4 Controlled Foreign Corporations KUE anticipates that it and/or its subsidiaries will invest in non-U.S. operations. Depending upon the percentage of ownership of such operations by

urged to consult their own tax advisors regarding the tax consequences of an investment in Class A shares. Passive Foreign Investment Companies and Controlled Foreign Corporations. It is possible that we will invest in non-U.S. corporations treated as PFICs or CFCs. A PFIC is defined as any foreign corporation with respect to