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This is for general information purposes only and does not constitute legal advice. Prospective investors are hereby notified that any discussion of U.S. Federal tax issues contained or referred to in this document is not intended or written to be used, and cannot be used by prospective investors, for the purposes of avoiding penalties that may be imposed on them under the U.S. Internal Revenue Code of 1986, as amended; such document is being used in connection with the promotion or marketing by us of the transactions or matters addressed herein; and prospective investors should seek advice based on their particular circumstances from an independent tax advisor with respect to the application of the U.S. Federal income tax laws to their particular situations as well as any tax consequences arising under the U.S. Federal estate and gift tax laws, the laws of any state, local or foreign taxing jurisdiction, or under any applicable tax treaty.