Amendment #4 Page 307 of 868 tbele..91.fleffmkt appropriate claim for refund well the IRS Non-U S holders shouti corsut their tax advisors regarding ore applicable vntrholding tax rules aro tee posso,:ity of ottaning a refund at any over-withheld amounts Gain on disposition of shares of Class A common stock Subject to the discussion below on backupwenn:Ong and FATCA vnthrolckng, arty Sion realized by a non-U S holder on the sale. exchange or other deposition of shares d ow Class A cannon stock generally will not to suttect to United States federal income tax unless • the gain is eftectwely comected with a trade or business of the ron-U.S holder n the Umted States (and if required by an apple** income tax treaty. is attributable to a Unted Slates permanent establishment). • the non-U.S holder la an individual whoa preset in the United Sties fa 183 days or more n the taxable year of that digestion. and certain other caxl0ons are met et we are or have been a United States real property Poring corpowitort a USRFs4C.* for United Stales federal neon* tax purposes at any tme durirg the shorter of the five-year period erdrg on the date of the deposition or the period that the non-US holder held shares of our Class A common stock, or the appeal* period she case of a non-U.S holder desadoed in the first Cul lel pont above, any gun generally will be sutra to United States federal noome tax on a net income basis in the sane manner as i the non-U S holder were a Unred States person as defined under the Code (urges*, an app Cabe income tax treaty provides otherwise). and a non- U.S. holder that is a foreign corporation may also be subject to the branch profits tax at a rale of 30% on as effectively connected earrings and profits (tutted to adjustments), unless an applicable income tax treaty provides othenvse Except as otherwise provided by an applcatle intone tax treaty. an indmdual non-U.S holder described n the second bullet port above will be subject to a hat