For Charitable Remainder Trusts. If you are a “charitable remainder trust” within the meaning of Section 664 of the IRS Code, you acknowledge that you have reviewed the Prospectus and Statement of Additional Information, including any disclosure regarding whether any income you recognize from the Fund may be treated as unrelated business taxable income (“UBTI”), and you have discussed with your own tax and legal advisers the consequences to yourself and your beneficiaries of an investment in the Fund, including, if applicable, the risk that you may be subject to an excise tax in an amount equal to 100% of the amount of UBTI you recognize from your investment in the Fund.
For Charitable Remainder Trusts. If you are a “charitable remainder trust” within the meaning of Section 664 of the IRS Code, you acknowledge that you have reviewed the Memorandum for each Fund in which you are investing, including any disclosure regarding whether any income you recognize from the Fund may be treated as unrelated business taxable income (“UBTI”) and whether the Fund will be a passive foreign investment company, and you have discussed with your own tax and legal advisers the consequences to yourself and your beneficiaries of an investment in the Fund, including, if applicable, the risk that you may be subject to an excise tax in an amount equal to 100% of the amount of UBTI you recognize from your investment in the Fund and under the temporary regulation applicable to indirect owners in a passive foreign investment company.
