EFTA Document EFTA01451896

SOF III - 1081 Southern Financial LLC income would otherwise be excluded as dividends, interest, gains or other similar income. A U.S. Tax-Exempt Investor whose interest will be debt-financed should consult with its tax advisors concerning the taxation of such interest under the PFIC rules that may be applicable to its investment in the Offshore Feeder Fund. The Offshore Feeder Fund will be a PFIC as defined for U.S. federal income tax purposes. If an investor becomes a U.S. Taxable Invest