Cayman Islands Tax Considerations — Network — Epstein Files

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Cayman Islands Tax Considerations — Network — Epstein Files

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Cayman Islands Tax Considerations

U.S.

Cayman Islands

the United States

Issuer

the Cayman Islands

IRS

the Securities

Securities

the Form of Regulation S Global Notes

Transferees of Interests in Income Notes

Cleary Gottlieb Steen &

the Investment Company Act 71

United States Federal Income Taxes

Cleary Gottlieb Steen & Hamilton

Page Transferees of Interests in Senior Notes

the Co-Issuers

the Operating Guidelines

Transferees of Certificated Income Notes

assurance•

Material U.S. Federal Income Tax Considerations

Articles of Association

the Investment Management Agreement

Hamilton LLP

the District of Columbia

Cayman

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