Following the Money - Investment Frameworks and Expansion

Other LP Issues Affecting Terms • Bank Holding Company Act. • • 25% Ownership 5% Voting Tax-Exempt Investors Unrelated Business Taxable Income (UBTI) ● Borrowing to fund investments Investing in pass-through entities Receiving fees for service (fee offset provisions) Foreign Investors - - Effectively Connected Income (ECI) · Investing in pass-through entities Receiving fees for service Withholding on Distributions Morgan Lewis 30 30

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