Every indexed document

be required to file an IRS Form 5471 with the investor's U.S. federal

holders of Common LP Units could have additional

or is otherwise in accordance with the partner's interest in the

the General Partner and holders of the Profits Participation LP Units under

which is to return each Partner's capital contribution and then for all

although no assurance can be given in this regards. The

each Partner will be allocated its share of KUE's income or loss

KUE is not a taxable entity and incurs no U.S. federal income

or (5) any other person or entity that is treated for U.S. federal income tax

(3) an estate the income of which is subject to U.S. federal income taxation regardless of its

the term ""U.S. Person"" means (1) a citizen or resident of the U.S.

and any individual who is a non-U.S. Person (as defined

no law which is enacted in the Cayman Islands

no law which is enacted in the Cayman Islands

(including any officer or employee of a foreign

meaning it is primarily engaged in the production or

freely transferable and registered under some provisions of the

an entity's assets would not be considered

that plan will satisfy the diversification requirements of ERISA;

each investor will be required to represent whether or not it is a U.S.