Epstein File EFTA01376430: Treat and Manifest (DS10)

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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA01376430: Treat and Manifest (DS10)

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Document excerpt from a financial or securities agreement containing provisions regarding how an Issuer shall treat Senior Notes as debt and Income Notes as equity, and how collateral obligations shall be treated for tax accounting purposes, with reference to a Calculation Agent's determination subject to manifest error review.

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treat manifest

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Excerpt 1

(a) In the absence of controlling authority to the contrary, the Issuer shall **treat** the Senior Notes as debt of the Issuer and the Income Notes as equity

Excerpt 2

(d) The Issuer will **treat** each purchase of Collateral Obligations as a "purchase" for tax accounting and reporting purposes. 128 CONFIDENTIAL - PURSUANT

Excerpt 3

The Calculation Agent's determination of the foregoing rates and amounts for any Periodic Interest Accrual Period will (in the absence of **manifest** error