to become a publicly traded partnership within two years of this offering or the acquisition of KLC and 412. As a result, KUE does not believe the anti-inversion legislation or any regulations promulgated within the scope of the legislation’s regulatory authority should apply to KUE although no assurance can be given in this regard or with respect to any new acquisitions of or investments in U.S. corporations. In addition, KUE does not believe that any other Code provision subjecting non-U.S. corporations to U.S. federal income tax should apply to KUE or its subsidiaries, although no assurance can be in this regards. The promuigation of contrary regulations or a successful challenge of either of these positions by the Internal Revenue Service could materially reduce a holder's after-tax return and, thus, could result in a substantial reduction of the value of the Units. 6.2.6 Currency Fluctuations An investment in KUE is a U.S. dollar denominated investment. Contributions to and distributions from KUE will be made in U.S. doilars. Fluctuations in value between the U.S. dollar and the Investor's functional currency (if other than the U.S. dollar) may result in taxable income to the Investor. 6.2.7 Reporting Requirements Investors who are U.S. Persons will be required to file an IRS Form 8865 with the Investor's U.S. federal income tax return for the taxable year in which the Investor purchases the Common LP Units. Investors who are U.S. Persons may, depending upon the size of their investment in the General Partner, be required to file an IRS Form 5471 with the Investor's U.S. federal income tax return for the taxable year in which the Investor purchases Class A ordinary shares in the General Partner. Additionally, depending on the type of non-U.S. investments KUE makes, Investors who are U.S. Persons may be required to file additional IRS Forms such as a Form 54771 in subsequent years. 6.3. Risks Related to Projections 6.3.1 The projections included in this Memorand