defer payment of some or all of the taxes on the QEF's undistributed income subject to an interest charge on the deferred amount. Prospective purchasers of Income Notes should be aware that the Collateral Debt Obligations may be purchased by the Issuer with substantial original issue discount. As a result, the Issuer may have significant ordinary earnings from such instruments, but the receipt of cash attributable to such earnings may be deferred, perhaps for a substantial period of time. In addition, under certain circumstances. Interest Proceeds may be used to pay principal of the Senior Notes or to purchase additional Collateral Debt Obligations. Thus, absent an election to defer payment of taxes, U.S. holders that make a QEF election may owe tax on significant "phantom" income. The Issuer will provide, upon request, all information that a U.S. holder of Income Notes making a QEF election is required to obtain for U.S. federal income tax purposes (e.g.. the U.S. holder's pro rata share of ordinary income and net capital gain), will provide. upon request, a "PFIC Annual Information Statement" as described in Treasury Regulation 1.1295-1 (or in any successor IRS release or Treasury regulation), including all representations and statements required by such statement, and will take any other reasonable steps to facilitate such election. The Issuer shall also elect to calculate and report the amount and category of each type of long-term capital gain as provided in Section 1(h) of the Code that was recognized by the Issuer with respect to each taxable year of the Issuer. If a U.S. holder does not make a timely QEF election for the year in which it acquired its Income Notes and the PFIC rules are otherwise applicable, such holder will be subject to a special tax at ordinary, income rates on so- called "excess distributions." including both certain distributions from the Issuer and gain on the sale of Income Notes. The amount of income tax on excess dis