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SEC Filings

S-4
RENAISSANCE MEDIA GROUP LLC filed this Form S-4 on 06/12/1998
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Holder and will be increased by (i) any amounts included in income as OID, and
(ii) any market discount previously included in income by such Holder, and
decreased by (a) any principal and stated interest payments received by such
Holder, and (b) any amortized premium previously deducted from income by such
Holder. Except as described above with respect to market discount, such gain
or loss will be capital gain or loss. Capital gain or loss will be long-term
gain or loss if the Note is held by the United States Holder for more than one
year, otherwise such gain or loss will be short-term.
 
  United States Holders that are corporations will generally be taxed on net
capital gains at a maximum rate of 35%. In contrast, United States Holders
that are individuals will generally be taxed on net capital gains at a maximum
rate of (i) 28% for property held for 18 months or less but more than one
year, and (ii) 20% for property held more than 18 months. Special rules (and
generally lower maximum rates) apply for individuals in lower tax brackets.
Any capital losses realized by a United States Holder that is a corporation
generally may be used only to offset capital gains. Any capital losses
realized by a United States Holder that is an individual generally may be used
only to offset capital gains plus $3,000 of other income per year.
 
  Release of Obligors Upon Sale. Under certain circumstances, Renaissance
Louisiana or Renaissance Tennessee will be released and discharged from its
obligations in respect of the Notes upon the sale or other disposition of
Capital Stock in such Obligor to any Person that is not an Affiliate of the
Company. See "Description of the Notes--Release of Obligors Upon Sale." For
United States federal income tax purposes, a United States Holder will be
treated as having exchanged the Notes for new Notes if there is "significant
modification" of the debt instrument within the meaning of the Treasury
regulations, and in such case the Holder will be taxed on any gain or loss
determined in accordance with the discussion contained in "United States
Holders--Sale, Exchange or Redemption of the Notes" above. The deletion of a
co-obligor on the Notes will result in a "significant modification" if (i) as
a result of the deletion, there is a substantial impairment of the Company's
capacity to meet the payment obligations under the Notes, and (ii) the
Company's capacity to meet the payment obligations under the Notes was
adequate prior to the deletion and is primarily speculative after the
deletion. The Company's capacity to meet the payment obligations under the
Notes includes any source for payment, including collateral, guarantees, or
other credit enhancement. There are substantial limitations placed on the
ability of the Company to dispose of the Capital Stock in Renaissance
Louisiana or Renaissance Tennessee (see "Description of the Notes--Limitation
on Assets Sales"). If such disposition occurs, resulting in the release of one
of the Obligors, the Company does not believe that there will be a substantial
impairment of its capacity to meet the payment obligations under the Notes or
that such capacity will be primarily speculative, and thus that there will not
be a "significant modification" of the Notes.
 
FOREIGN HOLDERS
 
  The following is a general discussion of certain United States federal
income, estate and gift tax consequences of the ownership and sale or other
disposition of the Notes by any beneficial owner of a Note that is not a
United States Holder (a "Non-United States Holder"). Resident alien
individuals will be subject to United States federal income tax with respect
to the Notes as if they were United States Holders.
 
  Interest. Under current United States federal income tax law, and subject to
the discussion of backup withholding below, interest (including OID) paid on
the Notes to a Non-United States Holder will not be subject to the normal 30%
United States federal withholding tax; provided that (i) the interest is
"effectively connected with the conduct of a trade or business in the United
States" by the Non-United States Holder and the Non-United States Holder
timely furnishes the Obligors with two duly executed copies of Internal
Revenue Service Form 4224 (or any successor form), or (ii) all of the
following conditions of the "portfolio interest" exception (the "Portfolio
Interest Exception") are met: (A) the Non-United States Holder does not,
actually or constructively, own 10% or more of the total combined voting power
of all classes of stock of a corporate issuer entitled to vote and does not,
actually or constructively, own 10% or more of the capital or profits interest
in a partnership issuer, (B) the Non-United States Holder is not a controlled
foreign corporation that is related, directly or indirectly, to the Obligors
through stock ownership, (C) the Non-United States Holder is not a bank
 
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