The document discusses the tax treatment of Subordinated Notes for U.S. and non-U.S. holders, including potential income tax characterization, unrelated business taxable income (UBTI) for tax-exempt U.S. holders, and withholding tax implications for non-U.S. holders. It also covers information reporting and backup withholding requirements, as well as reporting requirements for U.S. holders transferring property to foreign corporations.
documents/EFTA01365600.pdf
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