Cayman Islands Tax Considerations." All of the foregoing are subject to changc, and any change may apply retroactively and could affect the continued validity of this summary•, although it is expected that no changes will apply in the Cayman Islands due to the undertaking. As discussed in more detail below, withholding or deduction of taxes may be required in certain circumstances in respect of payments on the Securities. In the event that any such withholding or deduction of taxes is required. in any jurisdiction, neither of the Co-Issuers will be under any obligation to make any additional payments to the holders of the Securities in respect of such withholding or deduction. Prospective purchasers of the Securities should consult their own tax advisers as to U.S. federal income tax and Cayman Islands tax consequences of the purchase. ownership and disposition of the Securities, as well as the possible application of state, local. non-U.S. or other tax laws. Certain Material U.S. Federal Income Tax Considerations As used in this section. the term "U.S. holder- means a beneficial owner of a Security that is. for U.S. federal income tax purposes, a citizen or individual resident of the United States, a corporation (or other entity treated as a corporation for U.S. federal income tax purposes) that was organized under the laws of the United States, any state thereof, or the District of Columbia. any estate the income of which is subject to U.S. federal income tax regardless of the source of its income or any trust if a court within the United States is able to exercise primary supervision over the administration of the trust and one or more U.S. persons have the authority to control all substantial decisions of the trust. If a partnership (or other entity treated as a partnership for U.S. federal income tax purposes) holds Securities. the U.S. federal income tax treatment of a partner generally will depend upon the status of the partner and upon the