The document discusses tax implications for the Issuer related to withholding taxes and compliance with U.S. tax laws. It outlines potential withholding tax liabilities on payments made to the Issuer, especially in relation to U.S. Collateral Obligations and the need for information reporting agreements with the IRS. The document also covers the consequences of the Issuer being classified as a passive foreign investment company and the tax obligations of U.S. holders of Subordinated Securities.
doj/DataSet10/EFTA01376291.pdf
{"document_type":"legal","key_locations":["United States"],"key_organizations":["Issuer","IRS"]}