...In this respect, the Cayman Islands and the United States on November 29, 2013 entered into an intergovernmental agreement with respect to FATCA implementation (the "Cayman IGA") under which the Underlying Fund may be required to obtain and provide to the Cayman Islands government certain information from each of its...

...We satisfied the REIT distribution requirements for 1990 through 2012 where necessary by attributing distributions in 1991 through 2013 to the prior year's taxable income. We may be required to continue this pattern of making distributions after the close of a taxable year that are attributed to the prior...