Form 3520-A
Attached is a sample of an IRS Form 3520-A with respect to ownership of trust certificates (“Trust Certificates”) that is based on what was issued by the Lamington Road Grantor Trust, a Cayman Islands grantor trust (the “Grantor Trust”) to another certificate holder. Such IRS Form 3520-A was prepared by the accounting firm retained by the Trustee of the Grantor Trust. This sample is intended to provide the basis to derive the necessary information to complete a Substitute IRS Form 3520-A with respect to an interest in such Trust Certificates in the event that (i) you have determined that you are required to file an IRS Form 3520 with respect to your interest in the Trust Certificates and (ii) you have not received an IRS Form 3520-A directly from the trustee of the Grantor Trust. For purposes of completing a Substitute Form 3520-A, please note that there are 171,541,491 Trust Certificates outstanding (which correspond to 171,541,491 PPNs issued by Lamington Road DAC).
This is not intended to provide any guidance as to the U.S. federal income tax consequences of owning Trust Certificates, including whether holders of such Trust Certificates are required to file an IRS Form 3520. Each holder of Trust Certificates should consult with its own tax advisor regarding the U.S. federal, state, local and non-U.S. tax treatment to it from owning Trust Certificates.