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returns, and might be liable for U.S. tax in excess of the amount collected by withholding.
Similarly, Non-U.S. Partners could become subject to U.S. federal income tax and tax return
filing obligations, as a result of transfers of their Limited Partner Interests at a time when the
Fund owned stock of any U.S. corporation that is a USRPHC, although certain exceptions may
apply. Even if a company in which the Fund invests is not a USRPHC at the time of such
investment, such company subsequently may become a USRPHC.

Currency Conversion Issues - Non-U.S. Partners (like other Partners) will be required to make
their capital contributions to the Fund in U.S. dollars, and any cash distributions made by the
Fund will be made in U.S. dollars. Profits or losses realized by Non-U.S. Partners on the
conversion of other currencies into U.S. dollars, or of U.S. dollars into other currencies, will
neither be reflected in the capital accounts of the Partners nor affect the amounts distributable
by the Fund to its Non-U.S. Partners.

Withholding on Payments to Certain Foreign Entities - Sections 1471 through 1474 of the Code
would generally impose a withholding tax of 30% on certain gross amounts of income not
effectively connected with a U.S. trade or business paid to certain foreign entities, unless certain
requirements are satisfied. Amounts subject to withholding tax under these rules generally
include gross U.S.-source dividend and interest income paid on or after July 1, 2014, as well as
gross proceeds from the sale of property that produces U.S.-source dividend or interest income
paid on or after January 1, 2017. To avoid withholding under these rules, Non-U.S. Partners
that are subject to these rules will generally be obligated to comply with certain information
reporting and disclosure requirements, including, in certain cases, entering into an agreement
with the IRS. Non-U.S. Partners are encouraged to consult their own tax advisors regarding the
possible application of Sections 1471 through 1474 of the Code to their investment in the Fund.

Other Tax Matters

Certain State and Local Tax Consequences - State and local taxing jurisdictions may impose
income taxes and estate, inheritance and intangible property taxes on income from, or an
investment in, the Fund. These tax laws may differ substantially from the U.S. federal tax laws.
As a result of participating in the Fund, a Partner may be required to file tax returns with, and
pay taxes to, any state or local jurisdiction in which the Fund does business (or is deemed to do
business from investing a portion of its commitments in operating businesses treated as tax
transparent for U.S. federal income tax purposes). A Partner’s distributive share of the Fund’s
taxable income, gain, loss, deduction and credit is normally included in the income reported to
the state and local jurisdiction(s) in which the Partner is a resident or does business. Investors
should consult their own tax advisors about state and local taxes.

Basis for Description of Tax Consequences - The description of U.S. tax consequences set forth
above is based on the provisions of the principal agreements relating to the Fund that the
General Partner expects will be adopted, existing provisions of the Code, existing and proposed
U.S. Treasury Regulations, existing administrative interpretations and court decisions, and
certain assumptions. Future legislation, U.S. Treasury Regulations, administrative
interpretations or court decisions could significantly change these authorities. Any such change
could have retroactive application and therefore could apply to transactions that have taken
place before such change occurs. In addition, some of the issues discussed above have not been
addressed by administrative authorities or resolved by the courts. Accordingly, no assurance

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