Extract to table

The co-issuance structure involving DUFC, a domestic corporation, introduces a source-of-income issue that must be carefully disclosed in the Offering Memorandum; however, to the extent payments are treated as U

Forms must be provided prior to the receipt of the first interest payment and must be renewed periodically

However, if a Guarantor is called upon to make a payment under its guarantee, the source of income and withholding tax consequences of that payment must be analyzed with reference to the jurisdiction of the paying Guarantor, as discussed in Section XI below

To qualify as QSI, interest must be unconditionally payable in cash or property (other than debt instruments of the issuer) at least annually at a single fixed rate

This is a critical calculation because, as demonstrated below, the result determines whether the OID on the Notes must be accrued

" Section 1273(a)(3) of the Code provides that "if the [OID] is less than [the de minimis amount], then [the stated redemption price at maturity] shall be treated as equal to the issue price