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sd-10-EFTA01366961Dept. of JusticeOther

EFTA Document EFTA01366961

Amendment #4 Page 532 of 868 IAA! . iff.c.81 we, canyfcrwards m Ina., are avalabe for an 8 year period from the penod in which trey were generated Cnna has net operating loss carrytorwarde foe income tax purposes of 55,541 which are available to offset future taxable income over a awe year prod In Inds where we had pretax income of $711 in 2014 and $2046 in 2013, we have a 100% rate reduction tax holiday when expres 15 years from the date of cornrissionng of Ire solar energy system and is

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Amendment #4 Page 532 of 868 IAA! . iff.c.81 we, canyfcrwards m Ina., are avalabe for an 8 year period from the penod in which trey were generated Cnna has net operating loss carrytorwarde foe income tax purposes of 55,541 which are available to offset future taxable income over a awe year prod In Inds where we had pretax income of $711 in 2014 and $2046 in 2013, we have a 100% rate reduction tax holiday when expres 15 years from the date of cornrissionng of Ire solar energy system and is

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Amendment #4 Page 532 of 868 IAA! . iff.c.81 we, canyfcrwards m Ina., are avalabe for an 8 year period from the penod in which trey were generated Cnna has net operating loss carrytorwarde foe income tax purposes of 55,541 which are available to offset future taxable income over a awe year prod In Inds where we had pretax income of $711 in 2014 and $2046 in 2013, we have a 100% rate reduction tax holiday when expres 15 years from the date of cornrissionng of Ire solar energy system and is available fora 10 year penod staring from the date on which the Frond earty starts claimrg the holiday The tar holiday is effect.* through March 31, 2026 In Malaysia. where we Nod pretax inCOIT* of $154 in 2014 and a Pretax loss of $1.570 in 2013 we have a tax holiday for all three protect entities allowing for accelerated tax deprecation on qualified solar assets placed in swine In Treiland, where we had pretax basses of $407 n 2014 and $488 in 2013, se have a 100% rate red.dion tax holiday for the first eagle years, and a 50% rate reduction tithe next free years The tax holiday e °linens through 2026 In South Africa, where we had pretax name of $106 an 2014 and a pretax loss of $1,562 in 2013, we have a tax holiday allowing for accelerated tax depreciation on qualified solar assets placed in service. In Chna. where we had a pretax loss of $3,059 and $2,373 in 2014 and 2013, respectively. we haves 100% rate reduction tax holiday for Ire first three years, and a 50% rate reduction for the next three years The tax holiday is efledwe through 2018 Rimini/ de to curl-R.48We losses. we determned that it was more likely ton not that certain net operating losses and otter deferred tax assets would not be realized in the f duce As a result. the valuation allowance against deferred tax assets was increased by 56.804 during 2014 The Company has no uncertain tax positions for 2013 and 2014 It is tie Company s policy to etude any reneges or Merest associated with uncertain tax embers n income tax expense 7. Derivative Instruments A summary of as ntcrest rate and currency swap instruments outstanding as of December 31, 2014 and 2013 is as follows Notional amount In boat currency Type of Instrument (in millionsl Notional currency Interest rate Variable rate Termination date Interest rate swap at • Economic Hedge 89 7 Malaysian Ringo 43% KLIBOR March 31. 2028 Interest rate swap *2 - Economic Hedge 357 Malaysian Ringgit 44% KLIBOR March 31. 2028 Interest rate swap S3 • Economic Heclge 173 0 Tree Bahl 65% MLR -2 0% December 31, 2023 Irserest rate swap e4 - Cash Flow Hedge Sottri African JBAR SAFE( 856.0 Rand 130% • 4 4% Septenter 33, 2031 attends swap - Sotth African JIBAR SAFEX LIBOR • Cash Fbw Hedge 856.0 Rand • 44% 2.2% September 30, 2031 F.212 http://cfdocs.btogo.com:27638/cf/drv7/pub/edgar/2015/07/20/0001193125-15-256461/d78... 7/20/2015 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0058489 CONFIDENTIAL SDNY_GM_00204673 EFTA01366961

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URLhttp://cfdocs.btogo.com:27638/cf/drv7/pub/edgar/2015/07/20/0001193125-15-256461/d78

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