RIN II • 094 Alpha Group Capital LLC foundations". Also, there are special considerations which should be taken into account by certain beneficiaries of charitable remainder trusts that invest in the Issuer. Charitable remainder trusts should consult their own tax advisers concerning the U.S. tax consequences of such an investment on their beneficiaries. Information Reporting and Backup Withholding Information reporting to the IRS generally will be required with respect to payments on the Preferred Shares and proceeds of the sale of the Preferred Shares by U.S. Holders other than corporations or other exempt recipients that establish their status as such. A "backup" withholding tax will apply to those payments if such U.S. Holder fails to provide certain identifying information (such as such U.S. Holders taxpayer identification number). Backup withholding is not an additional tax. The amount of any backup withholding collected from a payment will be allowed as a credit against the recipient's U.S. federal income tax liability and may entitle the recipient to a refund, so long as the required information is properly furnished to the IRS in a timely manner. U.S. Holders should consult their own tax advisors about any additional reporting requirements that may arise as a result of their purchasing, holding or disposing of Preferred Shares. Reporting Requirements Failure to comply with applicable reporting obligations could result in the imposition of substantial penalties and in some cases can result in an extension of the period during which the IRS may assess taxes. As discussed above, U.S. Holders should consult their tax advisors regarding the possibility of filing "protective" statements with their U.S. federal income tax returns regarding the treatment of the Issuer as a PFIC or CFC and consider the consequences to them if they fail to properly characterize the Issuer as a PFIC or CFC. Form 926. A U.S. Holder (including a U.S. tax-exempt entit