Tax Disclaimer and Cayman Tax Exemption Details for KUE Limited Partnership

18. CERTAIN INCOME TAX CONSEQUENCES The following summary of the taxation of KUE and the taxation of the Partners of KUE is based upon current law and does not purport to be a comprehensive discussion of all the tax considerations that may be relevant to a decision to purchase Units. Legislative, judicial or administrative changes may be forthcoming that could affect this summary. TO ENSURE COMPLIANCE WITH U.S. TREASURY DEPARTMENT REGULATIONS, WE ADVISE YOU THAT: (i) ANY DISCUSSION OF U.S. FEDERAL TAX ISSUES CONTAINED HEREIN IS NOT INTENDED OR WRITTEN TO BE RELIED UPON, AND CANNOT BE RELIED UPON, BY INVESTORS FOR THE PURPOSE OF AVOIDING TAX-RELATED PENALTIES UNDER THE U.S. INTERNAL REVENUE CODE OR APPLICABLE STATE OR LOCAL TAX LAW PROVISIONS; (ii) SUCH DISCUSSION IS BEING USED IN CONNECTION WITH THE PROMOTION OR MARKETING (WITHIN THE MEANING OF TREASURY REGULATIONS) BY THE COMPANY OF THE TRANSACTIONS OR MATTERS ADDRESSED HEREIN; (iii) INVESTORS SHOULD SEEK ADVICE BASED ON THEIR PARTICULAR CIRCUMSTANCES FROM AN INDEPENDENT TAX ADVISOR. PROSPECTIVE INVESTORS (INCLUDING ALL NON-U.S. PERSONS AS DEFINED BELOW) SHOULD CONSULT THEIR TAX ADVISORS CONCERNING THE U.S. FEDERAL, STATE, LOCAL, AND FOREIGN TAX CONSEQUENCES OF OWNING COMMON LP UNITS UNDER THE LAWS OF THEIR COUNTRIES OF CITIZENSHIP, RESIDENCE, ORDINARY RESIDENCE, OR DOMICILE. 18.1. Cayman Taxation There is, at present, no direct taxation in the Cayman Islands. The Government of the Cayman Islands, will not, under existing legislation, impose any income, corporate or capital gains tax, estate duty, inheritance tax, gift tax, or withholding tax upon KUE, its partners, the General Partner, or its shareholders. Similarly interest, dividends and gains payable to KUE and all distributions by KUE to its partners will be received free of any Cayman Islands income or withholding taxes. KUE has registered as an exempted limited partnership under Cayman Islands law and KUE has received an undertaking from the Governcr-in-Cabinet of the Cayman Islands to the effect that, for a period of 50 years fram the date of the undertaking, no law which is enacted in the Cayman Islands imposing any tax to be levied on profits or income or gains or appreciations shall apply to KUE or to any partner of KUE in respect of the operations or assets of KUE or the interest of a partner in KUE; and may further provide that any such taxes or any tax in the nature of estate duty or inheritance tax shall not be payable in respect of the obligations of KUE or the interests of the partners in KUE. The General Partner of KUE has registered as an exempted company under Cayman [slands law and the General Partner has received an undertaking from the Governor-in-Cabinet of the Cayman Islands that, in accordance with section 6 of the Tax Concessions Law (1999 Revision) of the Cayman Islands, for a pericd of 20 years from the date of the undertaking, no law which is enacted in the Cayman Islands imposing any tax to be levied cn profits, income, gains or appreciations or which is in the nature of estate duty or inheritance tax shall be payable (i) on the shares of the General Partner or (ii} by way of the withholding in whole or in part of a payment of dividend or other distribution of income or capital by the General Partner to its shareholders. The Cayman Islands does not have a double tax treaty with the United States or any other country. 140 HOUSE_OVERSIGHT_024573