Rapid Security AnalyzerSimplifying capital gains tax complexities globally through the use of an automated tool

B | Rapid Security AnalyzerB | Rapid Security Analyzer

Automating capital gains tax analysisWhat is the Rapid Security Analyzer?The Rapid Security Analyzer (RSA) automates the process of analyzing your portfolios for capital gains liabilities at the financial instrument level. The RSA’s reports reflect the tax rate and associated rules, (including netting rules) as well as the tax considerations noted with the status of each security. Additional features include (1) a dashboard that provides a broad overview of the findings by country, region and red, amber or green (RAG) status and (2) a side-by-side comparison of taxation of different fund types and tax rates by date.

Benefits of RSA

• Reduced time and cost of tax analysis

• Risk mitigation

• Improved accuracy and confidence

• Improved control and governance

• Enhanced ability to quickly make more- informed decisions

| Rapid Security Analyzer| Rapid Security Analyzer

Current portfolio review process

• Time- and labor-intensive

• Generally requires high-cost resources

• Increased exposure to risk

1Rapid Security Analyzer | 1Rapid Security Analyzer |

Robust and far-reaching information

1

1Rapid Security Analyzer | 1Rapid Security Analyzer | 1Rapid Security Analyzer |

74 jurisdictions of investment• South Africa

• Spain

• Sri Lanka

• Swaziland

• Sweden

• Switzerland

• Taiwan

• Thailand

• Turkey

• Ukraine

• United Arab Emirates

• UK

• US

• Vietnam

• Zambia

• Argentina

• Australia

• Austria

• Bahrain

• Bangladesh

• Belgium

• Bermuda

• Brazil

• Bulgaria

• Canada

• Cayman Islands

• Chile

• China

• Colombia

• Costa Rica

• Croatia

• Cyprus

• Czech Republic

• Denmark

• Ecuador

• Egypt

• Finland

• France

• Germany

• Greece

• Hong Kong

• Hungary

• Iceland

• India

• Indonesia

• Ireland

• Israel

• Italy

• Jamaica

• Japan

• Jersey, Channel Islands

• Korea

• Latvia

• Luxembourg

• Macau

• Malaysia

• Malta

• Mauritius

• Mexico

• Namibia

• Netherlands

• New Zealand

• Nigeria

• Norway

• Oman

• Panama

• Peru

• Philippines

• Poland

• Portugal

• Puerto Rico

• Romania

• Russia

• Singapore

Fund types• Bermuda Company

• Bermuda LP

• BVI Ltd.

• Canada MFT

• Cayman Exempt Company

• Cayman LP

• Cayman Ltd.

• Cayman Unit Trust

• Guernsey Corporation

• Irish Corp

• Jersey Corporation

• Luxembourg SARL

• Luxembourg SICAV/SICAF

• Scottish LP

• UK LP

• US LP

• US LLC

• US RIC

Instrument categories• Publicly traded debt

• Private debt

• Sovereign debt

• Private equity

• Publicly traded equity

• Depositary receipt

• Asset-backed security (real estate)

• Asset-backed security (non-real estate)

• Future

• Forward

• Swap

• Repo

2 | Rapid Security Analyzer2 | Rapid Security Analyzer

Asset ID Instrument name

Instrument type

Country of incorporation

Public/Private

# of shares (millions)

Unrealized gain/loss (US$)

Realized gain/loss (US$)

Country of investment

Instrument category Status Tax

rate

Current % of total value of shares held

Colum

General rule Netting rule

BQQCCT4 SBSN INDO III SOVEREIGN BOND INDONESIA PRIVATE 25.12 $731,844.79 Indonesia Sovereign debt R 20.0% 3.401%

Pursuant to domestic law, capital gains on debt are treated as interest and, therefore, subject to 20% withholding tax.

Gain and loss netting/offset is permitted. In practice, interest income can be deducted from a loss arising from a sale transaction for the purpose of calculating the final income tax payable.

BSS8410SAPIENS INTERNATIONAL CORP

EQUITY ISRAEL PUBLIC 0.2 ($86,261.88) ($308,273.22) Israel Publicly traded equity A 0% /

26.5% 0.411%

Pursuant to the Israel/Ireland treaty, capital gains from the alienation of portfolio investments are not taxable in Israel, except (1) where the investee company is land-rich, and (2) where the recipient has owned at least 10% of the capital at some time within the 12 months preceding the sale. If taxable, the rate is 26.5%. For treaty relief, consider treaty substance and procedural requirements.

Capital losses may be offset against capital gains. Furthermore, there is no requirement for the gains and losses to be from the same instrument type.

B563256 WHITEHORSE LTD FIXED INCOME CAYMAN ISLANDS PRIVATE 0.78 $1,284,433.86 Cayman

Islands Private debt G 0.0% 0.166% Capital gains are not subject to tax in the Cayman Islands. N/A

BKT2NP4 AVAGO TECHNE DERIVATIVE CROATIA PUBLIC 34 ($180,065.35) Singapore Forwards G 0.0% 12.297% Income derived from capital gains and paid to a

nonresident entity is not subject to tax in Croatia. N/A

Client provides RSA analysis

Ernst Young LLP Confidential 1 EY RSA_client DEMO_Designer7.xlsm

Innovation driving interactive results

Fund Asset ID Instrument category Country of investment Status Unrealized gain/loss (US$) Realized gain/loss (US$) Fund A B563256 Private debt Cayman Islands G 1,284,434$ Fund A B8S0TX3 Private debt United States G 3,206,908$ Fund A B7W82H1 Publicly traded equity Singapore G 2,446,308$ Fund A B99J925 Private debt Canada G (617,189)$ Fund A B8CHNW7 Publicly traded equity Cayman Islands G 6,567$ 1,226,519$ Fund A B4PHNB5 Publicly traded equity Bermuda G 6,567$ 1,226,516$ Fund A B89T0T2 Publicly traded equity India A 1,074,909$ Fund A BFZ1MV7 Publicly traded equity Greece A 4,473,467$ Fund A BBPL3F0 Publicly traded equity United Kingdom G 1,185,640$ Fund A BYRJ524 Publicly traded equity Panama G (180,065)$ Fund A BX36N28 Publicly traded equity Netherlands G 1,621,171$ Fund A BSS8410 Publicly traded equity Israel A (86,262)$ (308,273)$ Fund A B8FZD73 Publicly traded equity Netherlands G (42,060)$ (150,308)$ Fund A BNC9050 Publicly traded equity Netherlands G 50,700$ Fund A B42X0L5 Publicly traded equity Israel A 536,929$ Fund A BDSTXP5 Publicly traded equity Luxembourg G 120,557$ Fund A B3ZQFW0 Private equity Ireland G 70,174$ Fund A B84HK80 Publicly traded equity Greece A 166,112$ Fund A BQZJCV8 Publicly traded equity Switzerland A 213,368$ Fund A B976111 Publicly traded equity Argentina R 236,220$ Fund A BSKPG02 Publicly traded equity Indonesia R 272,447$ Fund A BP8GDX8 Publicly traded equity Indonesia R 91,723$ Fund A BJ4QPZ6 Publicly traded debt Canada G 134,391$ Fund A B79KMP8 Publicly traded debt Canada G 93,220$ Fund A BMJJJD7 Publicly traded debt Netherlands G 4,439$ Fund A 4595739 Sovereign debt Denmark G 30,998$

($2,000)

$0

$2,000

$4,000

$6,000

$8,000

$10,000

$12,000

$14,000

Private debt Publicly tradeddebt

Asset-backedsecurity (non-real estate)

Thou

sand

s

Unrealized gain/loss (US$) Realized gain/loss (US$)

Country of investment

Argentina

Bermuda

Canada

Cayman Islands

Colombia

Denmark

Region

Americas

Asia

Europe

($5,000) $0 $5,000 $10,000 $15,000

ArgentinaBermudaCanada

Cayman IslandsColombia

MexicoPanama

United StatesIndia

IndonesiaSingaporeDenmarkGermany

GreeceIreland

IsraelLuxembourgNetherlandsSwitzerland

United Kingdom

Amer

icas

Asia

Euro

pe

Thousands

Unrealized gain/loss (US$) Realized gain/loss (US$)13%

22%

66%

Status Red - significant tax considerations

Amber - potential tax considerations

Green - limited tax considerations

Status

Red - significant tax co...

Amber - potential tax co...

Green - limited tax cons...

Rapid Security AnalyzerExecutive dashboard

3Rapid Security Analyzer |

Asset ID Instrument name

Instrument type

Country of incorporation

Public/Private

# of shares (millions)

Unrealized gain/loss (US$)

Realized gain/loss (US$)

Country of investment

Instrument category Status Tax

rate

Current % of total value of shares held

Colum

General rule Netting rule

BQQCCT4 SBSN INDO III SOVEREIGN BOND INDONESIA PRIVATE 25.12 $731,844.79 Indonesia Sovereign debt R 20.0% 3.401%

Pursuant to domestic law, capital gains on debt are treated as interest and, therefore, subject to 20% withholding tax.

Gain and loss netting/offset is permitted. In practice, interest income can be deducted from a loss arising from a sale transaction for the purpose of calculating the final income tax payable.

BSS8410SAPIENS INTERNATIONAL CORP

EQUITY ISRAEL PUBLIC 0.2 ($86,261.88) ($308,273.22) Israel Publicly traded equity A 0% /

26.5% 0.411%

Pursuant to the Israel/Ireland treaty, capital gains from the alienation of portfolio investments are not taxable in Israel, except (1) where the investee company is land-rich, and (2) where the recipient has owned at least 10% of the capital at some time within the 12 months preceding the sale. If taxable, the rate is 26.5%. For treaty relief, consider treaty substance and procedural requirements.

Capital losses may be offset against capital gains. Furthermore, there is no requirement for the gains and losses to be from the same instrument type.

B563256 WHITEHORSE LTD FIXED INCOME CAYMAN ISLANDS PRIVATE 0.78 $1,284,433.86 Cayman

Islands Private debt G 0.0% 0.166% Capital gains are not subject to tax in the Cayman Islands. N/A

BKT2NP4 AVAGO TECHNE DERIVATIVE CROATIA PUBLIC 34 ($180,065.35) Singapore Forwards G 0.0% 12.297% Income derived from capital gains and paid to a

nonresident entity is not subject to tax in Croatia. N/A

Client provides RSA analysis

Ernst Young LLP Confidential 1 EY RSA_client DEMO_Designer7.xlsm

RSA provides results and insights based on client data• Verification of client-provided information

• Tax rates, associated tax rules and netting rules

• RAG status for each holding

• Red: significant tax considerations

• Amber: potential tax considerations

• Green: minimal tax considerations

Fund Asset ID Instrument category Country of investment Status Unrealized gain/loss (US$) Realized gain/loss (US$) Fund A B563256 Private debt Cayman Islands G 1,284,434$ Fund A B8S0TX3 Private debt United States G 3,206,908$ Fund A B7W82H1 Publicly traded equity Singapore G 2,446,308$ Fund A B99J925 Private debt Canada G (617,189)$ Fund A B8CHNW7 Publicly traded equity Cayman Islands G 6,567$ 1,226,519$ Fund A B4PHNB5 Publicly traded equity Bermuda G 6,567$ 1,226,516$ Fund A B89T0T2 Publicly traded equity India A 1,074,909$ Fund A BFZ1MV7 Publicly traded equity Greece A 4,473,467$ Fund A BBPL3F0 Publicly traded equity United Kingdom G 1,185,640$ Fund A BYRJ524 Publicly traded equity Panama G (180,065)$ Fund A BX36N28 Publicly traded equity Netherlands G 1,621,171$ Fund A BSS8410 Publicly traded equity Israel A (86,262)$ (308,273)$ Fund A B8FZD73 Publicly traded equity Netherlands G (42,060)$ (150,308)$ Fund A BNC9050 Publicly traded equity Netherlands G 50,700$ Fund A B42X0L5 Publicly traded equity Israel A 536,929$ Fund A BDSTXP5 Publicly traded equity Luxembourg G 120,557$ Fund A B3ZQFW0 Private equity Ireland G 70,174$ Fund A B84HK80 Publicly traded equity Greece A 166,112$ Fund A BQZJCV8 Publicly traded equity Switzerland A 213,368$ Fund A B976111 Publicly traded equity Argentina R 236,220$ Fund A BSKPG02 Publicly traded equity Indonesia R 272,447$ Fund A BP8GDX8 Publicly traded equity Indonesia R 91,723$ Fund A BJ4QPZ6 Publicly traded debt Canada G 134,391$ Fund A B79KMP8 Publicly traded debt Canada G 93,220$ Fund A BMJJJD7 Publicly traded debt Netherlands G 4,439$ Fund A 4595739 Sovereign debt Denmark G 30,998$

($2,000)

$0

$2,000

$4,000

$6,000

$8,000

$10,000

$12,000

$14,000

Private debt Publicly tradeddebt

Asset-backedsecurity (non-real estate)

Thou

sand

s

Unrealized gain/loss (US$) Realized gain/loss (US$)

Country of investment

Argentina

Bermuda

Canada

Cayman Islands

Colombia

Denmark

Region

Americas

Asia

Europe

($5,000) $0 $5,000 $10,000 $15,000

ArgentinaBermudaCanada

Cayman IslandsColombia

MexicoPanama

United StatesIndia

IndonesiaSingaporeDenmarkGermany

GreeceIreland

IsraelLuxembourgNetherlandsSwitzerland

United Kingdom

Amer

icas

Asia

Euro

pe

Thousands

Unrealized gain/loss (US$) Realized gain/loss (US$)13%

22%

66%

Status Red - significant tax considerations

Amber - potential tax considerations

Green - limited tax considerations

Status

Red - significant tax co...

Amber - potential tax co...

Green - limited tax cons...

Rapid Security AnalyzerExecutive dashboard

3Rapid Security Analyzer |

RSA provides the ability to create customized views of your investments

Fund Asset ID Instrument category Country of investment Status Unrealized gain/loss (US$) Realized gain/loss (US$) Fund A B7W82H1 Publicly traded equity Singapore G 2,446,308$ Fund A B89T0T2 Publicly traded equity India A 1,074,909$ Fund A BKT2NP2 Publicly traded equity Singapore G (180,065)$ Fund A BSKPG02 Publicly traded equity Indonesia R 272,447$ Fund A BP8GDX8 Publicly traded equity Indonesia R 91,723$ Fund A BQQCCT4 Sovereign debt Indonesia R 731,845$

$0

$500

$1,000

$1,500

$2,000

$2,500

$3,000

Publicly traded equity Sovereign debt

Thou

sand

s

Unrealized gain/loss (US$) Realized gain/loss (US$)

$0 $500 $1,000 $1,500 $2,000 $2,500

India

Indonesia

Singapore

Asia

Thousands

Unrealized gain/loss (US$) Realized gain/loss (US$)

50%

17%

33%

Asia StatusRed - significant tax considerations

Amber - potential tax considerations

Green - limited tax considerations

Fund Asset ID Instrument category Country of investment Status Unrealized gain/loss (US$) Realized gain/loss (US$) Fund A B7W82H1 Publicly traded equity Singapore G 2,446,308$ Fund A B89T0T2 Publicly traded equity India A 1,074,909$ Fund A BKT2NP2 Publicly traded equity Singapore G (180,065)$ Fund A BSKPG02 Publicly traded equity Indonesia R 272,447$ Fund A BP8GDX8 Publicly traded equity Indonesia R 91,723$ Fund A BQQCCT4 Sovereign debt Indonesia R 731,845$

$0

$500

$1,000

$1,500

$2,000

$2,500

$3,000

Publicly traded equity Sovereign debt

Thou

sand

s

Unrealized gain/loss (US$) Realized gain/loss (US$)

$0 $500 $1,000 $1,500 $2,000 $2,500

India

Indonesia

Singapore

Asia

Thousands

Unrealized gain/loss (US$) Realized gain/loss (US$)

50%

17%

33%Asia Status

Red - significant tax considerations

Amber - potential tax considerations

Green - limited tax considerations

Fund Asset ID Instrument category Country of investment Status Unrealized gain/loss (US$) Realized gain/loss (US$) Fund A B976111 Publicly traded equity Argentina R 236,220$ Fund A BSKPG02 Publicly traded equity Indonesia R 272,447$ Fund A BP8GDX8 Publicly traded equity Indonesia R 91,723$ Fund A BQQCCT4 Sovereign debt Indonesia R 731,845$

($2,000)

$0

$2,000

$4,000

$6,000

$8,000

$10,000

$12,000

$14,000

Private debt Publicly tradeddebt

Asset-backedsecurity (non-real estate)

Thou

sand

s

Unrealized gain/loss (US$) Realized gain/loss (US$)

($5,000) $0 $5,000 $10,000 $15,000

ArgentinaBermuda

CanadaCayman Islands

ColombiaMexico

PanamaUnited States

IndiaIndonesiaSingaporeDenmarkGermany

GreeceIreland

IsraelLuxembourgNetherlandsSwitzerland

United Kingdom

Amer

icas

Asia

Euro

pe

Thousands

Unrealized gain/loss (US$) Realized gain/loss (US$)

100%

Red Status Red - significant tax considerations

4 | Rapid Security Analyzer4 | Rapid Security Analyzer

Current fund type Potential type A Potential type B Potential types

4

• Cayman LP

• Luxembourg SARL

• Other fund types

• Irish Corp • UK LP• US LP

Forward-thinking and timely

Additional featuresSide-by-side comparisons by fund typeWhat would be the effect on your tax rates and rules if you could invest your current portfolio in any of the other investor countries (fund types) available in the RSA?

Side-by-side comparisons by effective dateWhat are the implications for rates and rules when investing your current portfolio on one date versus another?

19.5% tax rate

1 July–31 December 2015 1 January–20 June 2016

19% tax ratevs.

Historical date Current date

15%

18%

67%

37%

63%

13%

22%

66%

15%

18%

67%

5Rapid Security Analyzer | 5Rapid Security Analyzer | 5

Experience and innovation

Ask us about other tax technology tools to assist asset managers

The Global Withholding Tax Reporter™ (GWTR) is an online tax reference tool that provides current and historical withholding tax information about portfolio dividends, interest, capital gains and mutual fund distributions in 96 markets of investment in 206 markets of investors (limited entity types).

Please visit www.globaltaxreporter.com.

The PFIC Analyzer quickly identifies PFICs to assist funds in managing tax liabilities. Since launching the service in 2003, the PFIC Analyzer team has analyzed more than 150,000 foreign issuers for PFIC status and the service has evolved to include extensive hands-on involvement, combined with the vast resources of EY member firms globally.

More details are available at www.pficanalyzer.com.

Mark-to-Market (MTM) is a service that can provide a fund with MTM book and tax adjustments at 31 October, the fund’s fiscal year-end and interim periods (if needed for monitoring income volatility). The PFIC MTM service includes Forms 8621 and respective attachments for filing with the tax return.

PFIC MTM detailed report

Summary MTM schedule

Form 8621s and detailed attachments

© 2

013

EYGM

Lim

ited.

All

Righ

ts R

eser

ved.

EYG

# Y

Y301

9 1

309-

1127

301

NY

Automated PFIC mark-to-market service

OverviewStatutory guidance expressly allows mutual funds to mark all of their PFIC securities to market, whether held by the fund directly or indirectly. This election must be made in the initial year that the PFIC security was held by ling Form 8621 (Information Return by a Shareholder of a Passive Foreign Investment Company or Quali ed Electing Fund) with the original tax return for that year. “Late found” PFIC rules apply when the mark-to-market (MTM) election is made subsequent to the initial year of holding the PFIC stock.

PFIC MTM toolEY has developed an automated MTM tool that can provide a fund with MTM book/tax adjustments at 31 October and at the end of the fund’s scal year. The PFIC MTM Service will provide completed Forms 8621 and respective attachments to le with the tax return. Additionally, we can provide MTM exposure to the fund at various times during the year to help monitor the income volatility of PFIC holdings.

Our PFIC MTM team has deep experience in preparing and reviewing MTM calculations, including the impact of changes in PFIC status and corporate actions on the calculations.

Please contact the PFIC Analyzer Team for further information on the service and pricing.

Bene ts of the MTM Service • Cost-effective methodology —

streamlines the process of obtaining book/tax adjustments and tax return disclosures (Form 8621 and attachments) in an ef cient and timely manner

• Signi cant tax savings —compared to preparing MTM calculations manually in-house

• Ef cient monitoring — able to quantify impact of PFIC holdings at a given time for income projections and distribution planning

PFIC Analyzer TeamDanielle Clark+1 203 674 3693danielle.clark@ey.com

Mara Lamanna+1 203 674 3624mara.lamanna@ey.com

Chhaya Desai+1 949 437 0883chhaya.desai@ey.com

Stacy Villarreal+1 949 437 0882stacy.villarreal@ey.com

Passive Foreign Investment Company Analyzer

15%

18%

67%

Danielle Clarkdanielle.clark@ey.com +1 203 674 3693

Irina Pisarevairina.pisareva@ey.com +1 212 773 9349

Zsuzsanna Kadarzsuzsanna.kadar@ey.com +1 212 773 5453

Wendy Smithwendy.smith@ey.com +1 616 336 8254

Key Ernst & Young LLP contacts

Carter Vinsoncarter.vinson@ey.com +1 617 585 0961

Kevin J. Glenkevin.glen@ey.com +1 312 879 6257

Sajjad Qamarsajjad.qamar@ey.com +1 212 773 2318

Erin Vasilofferin.vasiloff@ey.com +1 216 583 1484

Dmitri V. Semenovdmitri.semenov@ey.com +1 212 773 2552

Stephanie Tanguaystephanie.tanguay@ey.com +1 617 585 0410

EY | Assurance | Tax | Transactions | Advisory

About EYEY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities.

EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organization, please visit ey.com.

© 2016 EYGM Limited.All Rights Reserved.

Score no. 00684-161Gbl 1604-1888641 BD FSOED None

This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax, or other professional advice. Please refer to your advisors for specific advice.

ey.com