This document discusses the risks related to taxation for non-U.S. investors, focusing on the potential limitations and challenges in utilizing Net Operating Losses (NOLS) to offset future taxable income. It highlights the impact of ownership changes on NOLS, the possibility of valuation allowances for deferred tax assets, and the tax implications of distributions to holders of Class A common stock.
documents/vol00010-efta01366529-pdf.pdf
{"title":"Amendment #4","document_date":"2015-07-20","document_type":"legal","document_subtype":"amendment","key_organizations":["IRS","SunEdison"],"reference_numbers":["DB-SDNY-0058057","SDNY_GM_00204241","EFTA01366529"]}