The document discusses the tax implications and legal considerations for an Issuer, particularly in relation to U.S. federal income taxes and withholding taxes. It highlights the potential risks of the Issuer being treated as engaged in a trade or business in the U.S., which could lead to substantial taxes. The role and liability of the Collateral Manager under the Collateral Management Agreement are also outlined. Additionally, it covers the tax treatment of U.S. holders of Class A Notes, including the treatment of interest and original issue discount (OID).
documents/vol00010-efta01365291-pdf.pdf
{"key_people":["Collateral Manager"],"document_type":"legal","key_locations":["United States","Cayman Islands"],"document_subtype":"tax opinion","key_organizations":["Cleary Gottlieb Steen & Hamilton LLP"]}