e Cayman Islands has also (i) entered into an intergovernmental agreement with the United Kingdom, which imposes requirements similar to those under the Cayman IGA with respect to holders of the applicable Facility or Preferred Shares who are resident in the United Kingdom for tax purposes, and may enter into s

rtain information from each of its investors and meet certain other requirements. If the Underlying Master Fund complies with its obligations under the Cayman IGA, the Underlying Master Fund generally will not be subject to withholding under FATCA (and, for the avoidance of doubt, will not be required to enter