Extract to table

Based on VHG's reported Adjusted EBITDA of $412,000,000 for the last twelve months ended March 31, 2024, and VHG's scale of operations, we expect that the §163(j) limitation will not restrict the full deductibility of the annual interest expense of $41,250,000 on the Notes, although this conclusion depends on VHG's adjusted taxable income, which must be confirmed with VHG management and its independent auditors

Under the strict statutory language, OID must be "less than" (not "less than or equal to") the de minimis amount to qualify for de minimis treatment

Based on VHG's scale of operations, as reflected in its Adjusted EBITDA of $412,000,000, the §163(j) limitation is not expected to restrict the full deductibility of the interest expense on the Notes, although this conclusion must be confirmed based on VHG's actual adjusted taxable income

This alone does not cause AHYDO treatment; all three tests must be satisfied for the Notes to be classified as AHYDOs

The yield to maturity must be calculated based on the issue price of 98

263(a)-5(a)(2), amounts paid to facilitate the issuance of debt instruments must be capitalized