Extract to table

If the OID is not de minimis, it must be accrued into income by holders of the Notes on a constant-yield basis over the term of the Notes

The obligations must be in "registered form" within the meaning of Section 163(f) and the regulations thereunder

The interest on the Notes must not be contingent on, or determined by reference to, the income, profits, or assets of the Issuers or a related person

The certification must be furnished prior to the payment of interest and must be renewed or updated as required by the applicable Treasury Regulations (generally every three calendar years)

" The beneficial owner must not be a "10-percent shareholder" of the issuer within the meaning of Section 871(h)(3)(B)

The beneficial owner must not be a controlled foreign corporation ("CFC") that is related (within the meaning of Section 864(d)(4)) to the issuer