Common use of Non-U Clause in Contracts

Non-U. S. Investors The discussion below is applicable solely to Non-U.S. Persons investing directly with the Company. Xxxxxxx Homes Xxxxxxx Loans, LLC (the Company) will be required to withhold U.S. Federal income tax at the rate of up to thirty percent (30%), or lower treaty rate, if applicable on a Non U.S. Persons distributive share of any U.S. source Distributions the Company realizes and certain limited types of U.S. source interest. Withholding generally is not currently required with respect to gain from the sale of portfolio securities. The Company will, however, be required to withhold on the amount of gain realize on the disposition of a U.S. real property interest included in a Non U.S. Persons Distribution at a rate of up to thirty nine percent (39%). Each Non U.S. Person that invests in this Offering will be required to file a U.S. Federal income tax return reporting such gain. The Gain realized on the sale of all or any portion of a Membership Interest will, to the extent such gain is attributable to U.S. real property interests, be subject to U.S. income tax. The Company will be required to withhold U.S. Federal income tax at the highest rate applicable for any effectively connected taxable income (as that term is defined by the IRS) allocated to a Non U.S. Person, and the amount withheld will be available as a credit against the tax shown on such Persons return. The computation of income effectively connected with the Company may be different from the computation of the Non U.S. Persons effectively connected income (because, for example, when computing the Companys effectively connected income, net operating Losses from prior years are not available to offset the Companys current income), so in any given year the Company may be required to withhold tax with respect to its Non U.S. Person Investors in excess of their individual Federal income tax liability for the year. If a Non U.S. Person invests through an entity, it may be subject to the thirty percent (30%) branch profits tax on its effective connected income. The branch profits tax is a tax on the dividend equivalent amount of a non U.S. corporation Xxxxxxx Homes Xxxxxxx Loans | 60 Company Operating Agreement

Non-U. S. Investors The discussion below is applicable solely to Non-U.S. Persons investing directly with the Company. Xxxxxxx Homes Xxxxxxx Loans, LLC (the Company) The Company will be required to withhold U.S. Federal income tax at the rate of up to thirty percent (30%), or lower treaty rate, if applicable on a Non Non-U.S. Persons Person’s distributive share of any U.S. source Distributions the Company realizes and certain limited types of U.S. source interest. Withholding generally is not currently required with respect to gain from the sale of portfolio securities. The Company will, however, be required to withhold on the amount of gain realize realized on the disposition of a “U.S. real property interest interest” included in a Non Non-U.S. Persons Person’s Distribution at a rate of up to thirty nine thirty-five percent (3935%). Each Non Non-U.S. Person that invests in this Offering will be required to file a U.S. Federal income tax return reporting such gain. The Gain realized on the sale of all or any portion of a Membership Interest will, to the extent such gain is attributable to U.S. real property interests, be subject to U.S. income tax. The Company will be required to withhold U.S. Federal income tax at the highest rate applicable for any “effectively connected taxable income income” (as that term is defined by the IRS) allocated to a Non Non-U.S. Person, and the amount withheld will be available as a credit against the tax shown on such Persons Person’s return. The computation of income effectively connected with the Company may be different from the computation of the Non Non-U.S. Persons Person’s effectively connected income (because, for example, when computing the Companys Company’s effectively connected income, net operating Losses from prior years are not available to offset the Companys Company’s current income), so in any given year the Company may be required to withhold tax with respect to its Non Non-U.S. Person Person-Investors in excess of their individual Federal income tax liability for the year. If a Non Non-U.S. Person invests through an entity, it may be subject to the thirty percent (30%) branch profits tax on its effective effectively connected income. The branch profits tax is a tax on the “dividend equivalent amount” of a non-U.S. corporation (which may apply in the case of a limited liability company), which is approximately equal to the amount of such Company’s earnings and profits attributable to effectively connected income that is not treated as reinvested in the U.S. The effect of the branch profits tax is to increase the maximum U.S. Federal income tax rate on effectively connected income from thirty-five percent (35%) to over fifty percent (50%). Some U.S. income tax treaties provide exemptions from, or reduced rates for, the branch profits tax for “qualified residents” of the treaty country. The branch profits tax may also apply if a non Non-U.S. corporation Xxxxxxx Homes Xxxxxxx Loans | 60 Person claims deductions against their effectively connected income from the Company Operating Agreementfor interest on indebtedness of its non-U.S. Member. The Company is authorized to withhold and pay over any withholding taxes and treat such withholding as a payment to the Non-U.S. Person if the withholding was required. Such payment will be treated as a Distribution to the extent that the Non-U.S. Person is then entitled to receive a Distribution. To the extent that the aggregate of such payments to a Non-U.S. Person for any period exceeds the Distributions to which they are entitled for such period, the Company will notify the Non-U.S. Person as to the amount of such excess and the amount of such excess will be treated as a loan by the Company to the Non-U.S. Person. If a Non-U.S. Person owns a Membership Interest directly on the date of death, its estate could be further subject to U.S. estate tax with respect to such Interest.

Non-U. S. Investors The discussion below is applicable solely to Non-U.S. Persons investing directly with the Company. Xxxxxxx Homes Xxxxxxx Loans, LLC (the Company) The Company will be required to withhold U.S. Federal income tax at the rate of up to thirty percent (30%), or lower treaty rate, if applicable on a Non Non-U.S. Persons Person’s distributive share of any U.S. source Distributions the Company realizes and certain limited types of U.S. source interest. Withholding generally is not currently required with respect to gain from the sale of portfolio securities. The Company will, however, be required to withhold on the amount of gain realize realized on the disposition of a “U.S. real property interest interest” included in a Non Non-U.S. Persons Person’s Distribution at a rate of up to thirty nine percent (3930%). Each Non Non-U.S. Person that invests in this Offering will be required to file a U.S. Federal income tax return reporting such gain. The Gain realized on the sale of all or any portion of a Membership Interest will, to the extent such gain is attributable to U.S. real property interests, be subject to U.S. income tax. The Company will be required to withhold U.S. Federal income tax at the highest rate applicable for any “effectively connected taxable income income” (as that term is defined by the IRS) allocated to a Non Non-U.S. Person, and the amount withheld will be available as a credit against the tax shown on such Persons Person’s return. The computation of income effectively connected with the Company may be different from the computation of the Non Non-U.S. Persons Person’s effectively connected income (because, for example, when computing the Companys Company’s effectively connected income, net operating Losses from prior years are not available to offset the Companys Company’s current income), so in any given year the Company may be required to withhold tax with respect to its Non Non-U.S. Person Person-Investors in excess of their individual Federal income tax liability for the year. If a Non Non-U.S. Person invests through an entity, it may be subject to the thirty percent (30%) branch profits tax on its effective effectively connected income. The branch profits tax is a tax on the “dividend equivalent amount” of a non-U.S. corporation (which may apply in the case of a limited liability company), which is approximately equal to the amount of such Company’s earnings and profits attributable to effectively connected income that is not treated as reinvested in the U.S. The effect of the branch profits tax is to increase the maximum U.S. Federal income tax rate on effectively connected income from thirty percent (30%) to over fifty percent (50%). Some U.S. income tax treaties provide exemptions from, or reduced rates for, the branch profits tax for “qualified residents” of the treaty country. The branch profits tax may also apply if a non Non-U.S. corporation Xxxxxxx Homes Xxxxxxx Loans | 60 Person claims deductions against their effectively connected income from the Company Operating Agreementfor interest on indebtedness of its non-U.S. Member. The Company is authorized to withhold and pay over any withholding taxes and treat such withholding as a payment to the Non-U.S. Person if the withholding was required. Such payment will be treated as a Distribution to the extent that the Non-U.S. Person is then entitled to receive a Distribution. To the extent that the aggregate of such payments to a Non-U.S. Person for any period exceeds the Distributions to which they are entitled for such period, the Company will notify the Non-U.S. Person as to the amount of such excess and the amount of such excess will be treated as a loan by the Company to the Non-U.S. Person. If a Non-U.S. Person owns a Membership Interest directly on the date of death, its estate could be further subject to U.S. estate tax with respect to such Interest.

Non-U. S. Investors The discussion below is applicable solely to Non-U.S. Persons investing directly with the Company. Xxxxxxx Homes Xxxxxxx Loans, LLC (the Company) The Company will be required to withhold U.S. Federal income tax at the rate of up to thirty percent (30%), or lower treaty rate, if applicable on a Non Non-U.S. Persons Person’s distributive share of any U.S. source Distributions the Company realizes and certain limited types of U.S. source interest. Withholding generally is not currently required with respect to gain from the sale of portfolio securities. The Company will, however, be required to withhold on the amount of gain realize realized on the disposition of a “U.S. real property interest interest” included in a Non Non-U.S. Persons Person’s Distribution at a rate of up to thirty thirty-nine percent (39%). Each Non Non-U.S. Person that invests in this Offering will be required to file a U.S. Federal income tax return reporting such gain. The Gain realized on the sale of all or any portion of a Membership Interest will, to the extent such gain is attributable to U.S. real property interests, be subject to U.S. income tax. The Company will be required to withhold U.S. Federal income tax at the highest rate applicable for any “effectively connected taxable income income” (as that term is defined by the IRS) allocated to a Non Non-U.S. Person, and the amount withheld will be available as a credit against the tax shown on such Persons Person’s return. The computation of income effectively connected with the Company may be different from the computation of the Non Non-U.S. Persons Person’s effectively connected income (because, for example, when computing the Companys Company’s effectively connected income, net operating Losses from prior years are not available to offset the Companys Company’s current income), so in any given year the Company may be required to withhold tax with respect to its Non Non-U.S. Person Person-Investors in excess of their individual Federal income tax liability for the year. Tulsa Real Estate Fund, LLC C-8 Company Agreement If a Non Non-U.S. Person invests through an entity, it may be subject to the thirty percent (30%) branch profits tax on its effective effectively connected income. The branch profits tax is a tax on the “dividend equivalent amount” of a non-U.S. corporation (which may apply in the case of a limited liability company), which is approximately equal to the amount of such Company’s earnings and profits attributable to effectively connected income that is not treated as reinvested in the U.S. The effect of the branch profits tax is to increase the maximum U.S. Federal income tax rate on effectively connected income from thirty-five percent (35%) to over fifty percent (50%). Some U.S. income tax treaties provide exemptions from, or reduced rates for, the branch profits tax for “qualified residents” of the treaty country. The branch profits tax may also apply if a non Non-U.S. corporation Xxxxxxx Homes Xxxxxxx Loans | 60 Person claims deductions against their effectively connected income from the Company Operating Agreementfor interest on indebtedness of its non-U.S. Member. The Company is authorized to withhold and pay over any withholding taxes and treat such withholding as a payment to the Non-U.S. Person if the withholding was required. Such payment will be treated as a Distribution to the extent that the Non-U.S. Person is then entitled to receive a Distribution. To the extent that the aggregate of such payments to a Non-U.S. Person for any period exceeds the Distributions to which they are entitled for such period, the Company will notify the Non-U.S. Person as to the amount of such excess and the amount of such excess will be treated as a loan by the Company to the Non-U.S. Person. If a Non-U.S. Person owns a Membership Interest directly on the date of death, its estate could be further subject to U.S. estate tax with respect to such Interest.

Non-U. S. Investors The discussion below is applicable solely to Non-U.S. Persons investing directly with the Company. Xxxxxxx Homes Xxxxxxx Loans, LLC (the Company) The Company will be required to withhold U.S. Federal income tax at the rate of up to thirty percent (30%), or lower treaty rate, if applicable on a Non Non-U.S. Persons Person’s distributive share of any U.S. source Distributions the Company realizes and certain limited types of U.S. source interest. Withholding generally is not currently required with respect to gain from the sale of portfolio securities. The Company will, however, be required to withhold on the amount of gain realize realized on the disposition of a “U.S. real property interest interest” included in a Non Non-U.S. Persons Person’s Distribution at a rate of up to thirty thirty-nine percent (39%). Each Non Non-U.S. Person that invests in this Offering will be required to file a U.S. Federal income tax return reporting such gain. The Gain realized on the sale of all or any portion of a Membership Interest will, to the extent such gain is attributable to U.S. real property interests, be subject to U.S. income tax. The Company will be required to withhold U.S. Federal income tax at the highest rate applicable for any “effectively connected taxable income income” (as that term is defined by the IRS) allocated to a Non Non-U.S. Person, and the amount withheld will be available as a credit against the tax shown on such Persons Person’s return. The computation of income effectively connected with the Company may be different from the computation of the Non Non-U.S. Persons Person’s effectively connected income (because, for example, when computing the Companys Company’s effectively connected income, net operating Losses from prior years are not available to offset the Companys Company’s current income), so in any given year the Company may be required to withhold tax with respect to its Non Non-U.S. Person Person-Investors in excess of their individual Federal income tax liability for the year. Paradyme Equities, LLC C-8 Company Agreement If a Non Non-U.S. Person invests through an entity, it may be subject to the thirty percent (30%) branch profits tax on its effective effectively connected income. The branch profits tax is a tax on the “dividend equivalent amount” of a non-U.S. corporation (which may apply in the case of a limited liability company), which is approximately equal to the amount of such Company’s earnings and profits attributable to effectively connected income that is not treated as reinvested in the U.S. The effect of the branch profits tax is to increase the maximum U.S. Federal income tax rate on effectively connected income from thirty-five percent (35%) to over fifty percent (50%). Some U.S. income tax treaties provide exemptions from, or reduced rates for, the branch profits tax for “qualified residents” of the treaty country. The branch profits tax may also apply if a non Non-U.S. corporation Xxxxxxx Homes Xxxxxxx Loans | 60 Person claims deductions against their effectively connected income from the Company Operating Agreementfor interest on indebtedness of its non-U.S. Member. The Company is authorized to withhold and pay over any withholding taxes and treat such withholding as a payment to the Non-U.S. Person if the withholding was required. Such payment will be treated as a Distribution to the extent that the Non-U.S. Person is then entitled to receive a Distribution. To the extent that the aggregate of such payments to a Non-U.S. Person for any period exceeds the Distributions to which they are entitled for such period, the Company will notify the Non-U.S. Person as to the amount of such excess and the amount of such excess will be treated as a loan by the Company to the Non-U.S. Person. If a Non-U.S. Person owns a Membership Interest directly on the date of death, its estate could be further subject to U.S. estate tax with respect to such Interest.

Non-U. S. Investors The discussion below is applicable solely to Non-U.S. Persons investing directly with the Company. Xxxxxxx Homes Xxxxxxx Loans, LLC (the Company) The Company will be required to withhold U.S. Federal income tax at the rate of up to thirty percent (30%), or lower treaty rate, if applicable on a Non Non-U.S. Persons Person’s distributive share of any U.S. source Distributions the Company realizes and certain limited types of U.S. source interest. Withholding generally is not currently required with respect to gain from the sale of portfolio securities. The Company will, however, be required to withhold on the amount of gain realize realized on the disposition of a “U.S. real property interest interest” included in a Non Non-U.S. Persons Person’s Distribution at a rate of up to thirty thirty-nine percent (39%). Each Non Non-U.S. Person that invests in this Offering will be required to file a U.S. Federal income tax return reporting such gain. The Gain realized on the sale of all or any portion of a Membership Interest will, to the extent such gain is attributable to U.S. real property interests, be subject to U.S. income tax. The Company will be required to withhold U.S. Federal income tax at the highest rate applicable for any “effectively connected taxable income income” (as that term is defined by the IRS) allocated to a Non Non-U.S. Person, and the amount withheld will be available as a credit against the tax shown on such Persons Person’s return. The computation of income effectively connected with the Company may be different from the computation of the Non Non-U.S. Persons Person’s effectively connected income (because, for example, when computing the Companys Company’s effectively connected income, net operating Losses from prior years are not available to offset the Companys Company’s current income), so in any given year the Company may be required to withhold tax with respect to its Non Non-U.S. Person Person-Investors in excess of their individual Federal income tax liability for the year. If a Non Non-U.S. Person invests through an entity, it may be subject to the thirty percent (30%) branch profits tax on its effective effectively connected income. The branch profits tax is a tax on the “dividend equivalent amount” of a non-U.S. corporation (which may apply in the case of a limited liability company), which is approximately equal to the amount of such Company’s earnings and profits attributable to effectively connected income that is not treated as reinvested in the U.S. The effect of the branch profits tax is to increase the maximum U.S. Federal income tax rate on effectively connected income from thirty-five percent (35%) to over fifty percent (50%). Some U.S. income tax treaties provide exemptions from, or reduced rates for, the branch profits tax for “qualified residents” of the treaty country. The branch profits tax may also apply if a non Non-U.S. corporation Xxxxxxx Homes Xxxxxxx Loans | 60 Person claims deductions against their effectively connected income from the Company Operating Agreementfor interest on indebtedness of its non-U.S. Member. The Company is authorized to withhold and pay over any withholding taxes and treat such withholding as a payment to the Non-U.S. Person if the withholding was required. Such payment will be treated as a Distribution to the extent that the Non-U.S. Person is then entitled to receive a Distribution. To the extent that the aggregate of such payments to a Non-U.S. Person for any period exceeds the Distributions to which they are entitled for such period, the Company will notify the Non-U.S. Person as to the amount of such excess and the amount of such excess will be treated as a loan by the Company to the Non-U.S. Person. If a Non-U.S. Person owns a Membership Interest directly on the date of death, its estate could be further subject to U.S. estate tax with respect to such Interest.