EFTA01470570Set 10
2013-05-2422p6,087w
passive foreign investment company ("PFIC") or United States
real property holding corporation ("USRPHC"), both as defined for U.S.
federal income tax purposes. If one or more of the entities whose ... Reference Asset, as the case may be, is or becomes a
PFIC or a USRPHC.
Withholding and reporting requirements under the legislation enacted on
March 18, 2010 (as discussed beginning
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01470570.pdf