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S-4
RENAISSANCE MEDIA GROUP LLC filed this Form S-4 on 06/12/1998
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remain valid until the earlier of December 31, 2000 or the date of their
expiration. Existing certificates that expire in 1999 will not be effective
after their expiration. Certificates dated prior to January 1, 1998 will
generally remain valid until the end of 1998, irrespective of the fact that
their validity expires during 1998.
 
  In the event that the interest (including OID) paid on the Notes is
effectively connected with the conduct of a trade or business within the
United States of the Non-United States Holder, the Non-United States Holder
will generally be taxed on a net income basis (that is, after allowance for
applicable deductions) at the graduated rates that are applicable to United
States Holders in essentially the same manner as if the Notes were held by a
United States Holder, as discussed above. In the case of a Non-United States
Holder that is a corporation, such income may also be subject to the United
States federal branch profits tax (which is generally imposed on a foreign
corporation upon the deemed repatriation from the United States of effectively
connected earnings and profits) at a 30% rate, unless the rate is reduced or
eliminated by an applicable income tax treaty and the Non-United States Holder
is a qualified resident of the treaty country.
 
  If the interest on the Notes is not "effectively connected" and does not
qualify for the Portfolio Interest Exception, then the interest will be
subject to United States federal withholding tax at a flat rate of 30% (or a
lower applicable income tax treaty rate upon delivery of the appropriate
certification of eligibility for treaty benefits).
 
  Gain on Sale or Other Disposition. Subject to special rules applicable to
individuals as described below, a Non-United States Holder will generally not
be subject to regular United States federal income or withholding tax on gain
recognized on a sale or other disposition of the Notes (including a deemed
exchange upon a release of Obligors, as discussed above in "Certain United
States Federal Income Tax Consequences--United States Holders--Release of
Obligors Upon Sale"), unless the gain is effectively connected with the
conduct of a trade or business within the United States of the Non-United
States Holder or of a partnership, trust or estate in which such Non-United
States Holder is a partner or beneficiary.
 
  Gains realized by a Non-United States Holder that are effectively connected
with the conduct of a trade or business within the United States of the Non-
United States Holder will generally be taxed on a net income basis (that is,
after allowance for applicable deductions) at the graduated rates that are
applicable to United States Holders, as discussed above, unless exempt by an
applicable income tax treaty. In the case of a Non-United States Holder that
is a corporation, such income may also be subject to the United States federal
branch profits tax (which is generally imposed on a foreign corporation upon
the deemed repatriation from the United States of effectively connected
earnings and profits) at a 30% rate, unless the rate is reduced or eliminated
by an applicable income tax treaty and the Non-United States Holder is a
qualified resident of the treaty country.
 
  In addition to being subject to the rules described above, an individual
Non-United States Holder who holds the Notes as a capital asset will generally
be subject to tax at a 30% rate on any gain recognized on the sale or other
disposition of such Notes if (i) such gain is not effectively connected with
the conduct of a trade or business within the United States of the Non-United
States Holder, and (ii) such individual is present in the United States for
183 days or more in the taxable year of the sale or other disposition and
either (A) has a "tax home" in the United States (as specially defined for
purposes of the United States federal income tax), or (B) maintains an office
or other fixed place of business in the United States and the gain from the
sale or other disposition of the Notes is attributable to such office or other
fixed place of business. Individual Non-United States Holders may also be
subject to tax pursuant to provisions of United States federal income tax law
applicable to certain United States expatriates (including certain former
long-term residents of the United States).
 
  Under the 1997 Final Regulations, withholding of United States federal
income tax may apply to payments on a taxable sale or other disposition of the
Notes by a Non-United States Holder who does not provide appropriate
certification to the withholding agent with respect to such transaction.
 
  Federal Estate Taxes. A Note beneficially owned by an individual who is
neither a United States citizen nor a domiciliary of the United States at the
time of death will not be subject to United States federal estate tax
 
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