Extract to table

These provisions are critical to allocating withholding tax risk appropriately between the Borrower and the lenders and must be carefully coordinated with the gross-up and yield protection provisions expected in a market Term Loan B credit agreement

Each lender must independently determine its own U

To qualify for this exemption, the following conditions must be satisfied: (i) Registered Form Requirement

The obligation on which the interest is paid must be in "registered form" within the meaning of Section 163(f) of the Code and the Treasury Regulations thereunder

person receiving the interest must not be a "10-percent shareholder" of the borrower within the meaning of Section 871(h)(3)(B) of the Code

However, this determination must be made on a lender-by-lender basis, particularly if any non-U