Attentus CDO I Offering Circular - Irish Stock Exchange

ATTENTUS CDO I, LTD. (THE “COMPANY”)
(a) that no Law which is hereafter enacted in the Islands imposing any tax to be
levied on profits, income, gains or appreciations shall apply to the Company or its operations; and
(b) in addition, that no tax to be levied on profits, income, gains or appreciations or
which is in the nature of estate duty or inheritance tax shall be payable
(i)
Company; or
on or in respect of the shares debentures or other obligations of the
(ii) by way of the withholding in whole or in part of any relevant payment as
defined in Section 6(3) of The Tax Concessions Law (1999 Revision).
These concessions shall be for a period of TWENTY years from the date of issue.
Governor In Cabinet
The Cayman Islands does not have an income tax treaty arrangement with the U.S. or any other
country.
THE PRECEDING DISCUSSION IS ONLY A SUMMARY OF CERTAIN OF THE TAX
IMPLICATIONS OF AN INVESTMENT IN THE OFFERED NOTES. PROSPECTIVE
INVESTORS ARE URGED TO CONSULT WITH THEIR OWN TAX ADVISORS PRIOR TO
INVESTING TO DETERMINE THE TAX IMPLICATIONS OF SUCH INVESTMENT IN
LIGHT OF SUCH INVESTOR’S CIRCUMSTANCES.
CERTAIN ERISA CONSIDERATIONS
IRS Circular 230 Notice
To ensure compliance with Internal Revenue Service Circular 230, taxpayers are hereby notified
that: (A) any discussion of U.S. federal tax issues in this offering circular is not intended or written by us
to be relied upon, and cannot be relied upon by taxpayers for the purpose of avoiding penalties that may
be imposed on taxpayers under the Internal Revenue Code; (B) such discussion is written in connection
with the promotion or marketing of the transactions or matters addressed herein; and (C) taxpayers should
seek advice based on their particular circumstances from an independent tax advisor.
Senior Notes other than the Class E Notes
Subject to the following discussion, the Senior Notes (other than the Class E Notes and any
Senior Notes in the form of a Senior Note Component of any Combination Note) may be acquired by
pension, profit-sharing or other employee benefit plans, as well as individual retirement accounts, Keogh
plans and other plans covered by Section 4975 of the Code, as well as entities deemed to hold “plan
assets” of any of the foregoing (each a “Benefit Plan”). Section 406 of the Employee Retirement Income
Security Act of 1974, as amended (“ERISA”), and Section 4975 of the Code prohibit a Benefit Plan from
engaging in certain transactions with persons that are “parties in interest” under ERISA or “disqualified
persons” under the Code with respect to such Benefit Plan. A violation of these “prohibited transaction”
rules may result in an excise tax or other penalties and liabilities under ERISA and the Code for such
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