The document discusses tax considerations for securities in the Cayman Islands and the U.S. It highlights potential withholding or deduction of taxes on securities payments and advises prospective purchasers to consult tax advisers. It defines 'U.S. holder' and 'non-U.S. holder' for tax purposes and outlines the tax treatment of the issuer as a foreign corporation for U.S. federal income tax purposes. The issuer aims to avoid being treated as engaged in a U.S. trade or business to prevent U.S. federal income tax liability. The document includes a legal opinion from Cleary Gottlieb Steen & Hamilton LLP regarding the issuer's tax status, but notes potential risks and uncertainties.
documents/EFTA01365596.pdf
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