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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01376110: Holder and Cayman Islands (DS10)

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This document discusses Cayman Islands tax considerations and U.S. tax withholding requirements for holders of Class A Notes with Original Issue Discount (OID). It addresses the tax treatment obligations for U.S. holders of debt instruments issued by Cayman Islands entities.

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Excerpt 1
With respect to **Cayman** **Islands** taxation, see the discussion below in "-**Cayman** **Islands** Tax Considerations." Withholding Taxes.
Excerpt 2
If a U.S. **holder** acquires a Class A Note with OID, then regardless of such holder's method of accounting, the **holder** will be required to include such OID

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