Treasury regulations provide that the anti-inversion legislation is applicable to a foreign partnership that is or becomes a “publicly traded partnership” within two years of the acquisition by it of a U.S. corporation. A “publicly traded partnership” is any partnership (i) interests in which are traded on an established securities market, or (i) interests in which are readily tradabie on a secondary market (or the substantial equivalent thereof). KUE believes that it is not currently a publicly traded partnership and does not intend 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 investment 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 given in this regards. The promulgation 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. The remainder of this section assumes that KUE will be treated as a partnership for U.S. federal income tax purposes. 18.2.2 United States Federal Income Taxation of Partners U.S. Persons Allocation of Purchase Price. You will be treated as purchasing a Unit consisting of two components, one Common LP Unit and one GP Share. Your purchase price for each Unit will be allocated between one Common LP Unit and one GP Share in proportion to their relative fair market values at the time of your purchase, and this allocation will establish your initial tax basis in both you