Treatment of Securities. The Company will treat the Securities as indebtedness, and the amounts, other than payments of principal, payable in respect of the principal amount of such Securities as interest, for all U.S. federal income tax purposes. All payments in respect of the Securities will be made free and clear of U.S. withholding and back-up withholding tax to any beneficial owner thereof that has provided an Internal Revenue Service Form W-9 or W-8BEN (or any substitute or successor form) establishing its U.S. or non-U.S. status for U.S. federal income tax purposes, or any other applicable form establishing a complete exemption from U.S. withholding and back-up withholding tax.
Appears in 2 contracts
Samples: Junior Subordinated Indenture (Flagstone Reinsurance Holdings LTD), Junior Subordinated Indenture (Flagstone Reinsurance Holdings LTD)
Treatment of Securities. The Company will treat the Securities as indebtednessindebtedness of the Company, and the amounts, other than payments of principal, payable in respect of the principal amount of such Securities as interest, for all U.S. federal income tax purposespurposes unless otherwise required by law. All payments in respect of the Securities will be made free and clear of U.S. withholding and back-up withholding tax to any beneficial owner thereof that has provided an Internal Revenue Service Form W-9 or W-8BEN (or any substitute or successor form) establishing its U.S. or non-U.S. status for U.S. federal income tax purposes, or any other applicable form establishing a complete exemption from U.S. withholding and back-up withholding taxtax unless otherwise required by law.
Appears in 2 contracts
Samples: Junior Subordinated Indenture (Great Wolf Resorts, Inc.), Junior Subordinated Indenture (Great Wolf Resorts, Inc.)
Treatment of Securities. The Company will will, unless and until required otherwise by an applicable taxing authority, treat the Securities as indebtedness, and the amounts, other than payments of principal, payable in respect of the principal amount of such Securities as interest, for all U.S. United States federal income tax purposes. All payments in respect of the Securities will be made free and clear of U.S. withholding and back-up United States withholding tax to any beneficial owner thereof that has provided an Internal Revenue Service Form W-9 or W-8BEN (or any substitute or successor form) establishing its U.S. or non-U.S. status for U.S. United States federal income tax purposes, or any other applicable form establishing a complete exemption from U.S. withholding and back-up United States withholding tax.
Appears in 2 contracts
Samples: Junior Subordinated Indenture (Redwood Trust Inc), Subordinated Indenture (Redwood Trust Inc)
Treatment of Securities. The Company will treat the Securities as indebtedness, and the amounts, other than payments of principal, payable in respect of the principal amount of such Securities as interest, for all U.S. federal income tax purposes. All payments in respect of the Securities will be made free and clear of U.S. withholding and back-up withholding tax to any beneficial owner thereof that has provided an Internal Revenue Service Form W-9 or W-8BEN W-SBEN (or any substitute or successor form) establishing its U.S. or non-U.S. status for U.S. federal income tax purposes, or any other applicable form establishing a complete exemption from U.S. withholding and back-up withholding tax.
Appears in 1 contract
Samples: Junior Subordinated Indenture (Validus Holdings LTD)