6.2.2. Tax-Exempt and Non-U.5. Investors may become subject to U.S. Tax KUE business activities could generate income that will be taxable to certain otherwise tax-exempt Investors as “unrelated business taxable income.” Although, under the Limited Partnership Agreement, the General Partner is required to use its reasonable best efforts not to engage in, or invest in (other than through an entity that is not a pass-through entity) a pass-through entity that engages in, any activity which constitutes the conduct of a trade or business in the United States and generates income which constitutes “effectively connected income" in the hands of the non-US. Investors that own Common LP Units, itis possible that some of KUE’'s business activities and acquisitions could generate income that is “effectively connected” with a U.S. trade or business which could create U.S. federal income tax reporting, tax liability, and tax withholding for non-U.S. Investors. Additionally, KUE believes that neither KUE nor its subsidiaries is currently a U.S. Real Property Holding Corporation (“USRPHC") for U.S. federal income tax purposes. However, no assurances can be given in this regard. Furthermore, it is possible that in the future KUE and/or its subsidiaries may become a USRPHC if, for example, the value of the U.S. real estate holdings of KUE or such subsidiary increases sufficiently. A disposition of an interest in a USRPHC could create gain for non-U.S. Investors which would be treated as if the non-U.S. Investor were engaged in a trade or business within the U.S. and as if such gain were effectively connected with such trade or business. This would create U.S. federal income tax reporting, tax liability and withholding for non-U.S. Investors. Investors that are non-U.S. persons are urged to consult their tax advisors regarding the potential application of the USRPHC rules to their investment in KUE. 6.2.3. Investors may become subject to taxation in non-U.S. jurisdictions KUE expect