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SEC Filings

S-4/A
RENAISSANCE MEDIA GROUP LLC filed this Form S-4/A on 09/04/1998
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as a result of such individual's death; provided that any interest thereon
would have been eligible for the Portfolio Interest Exception described above
in "Certain United States Federal Income Tax Consequences--Foreign Holders--
Interest," if such interest had been received by the individual at the time of
death.
 
  Federal Gift Taxes. An individual who is not a United States citizen will
not be subject to United States federal gift tax on a transfer of Notes,
unless such person is a domiciliary of the United States or such person is
subject to provisions of United States federal gift tax law applicable to
certain United States expatriates (including certain former long-term
residents of the United States).
 
BACKUP WITHHOLDING TAX AND INFORMATION REPORTING
 
  Under current United States federal income tax law, information reporting
requirements apply to interest (including OID) paid to, and to the proceeds of
sales or other dispositions before maturity by, certain non-corporate persons.
In addition, a 31% backup withholding tax applies if a non-corporate person
(i) fails to furnish such person's Taxpayer Identification Number ("TIN")
(which, for an individual, is his or her Social Security Number) to the payor
in the manner required, (ii) furnishes an incorrect TIN and the payor is so
notified by the Service, (iii) is notified by the Service that such person has
failed properly to report payments of interest and dividends, or (iv) in
certain circumstances, fails to certify, under penalties of perjury, that such
person has not been notified by the Service that such person is subject to
backup withholding for failure properly to report interest and dividend
payments. Backup withholding does not apply to payments made to certain exempt
recipients, such as corporations and tax-exempt organizations.
 
  In the case of a Non-United States Holder, under current United States
federal income tax law, backup withholding and information reporting do not
apply to payments of interest (including OID) with respect to the Note, or to
payments on the sale or other disposition of a Note, if such Holder has
provided to the Obligors or their paying agent the certification described in
clause (ii)(D) of "Certain United States Federal Income Tax Consequences--
Foreign Holders--Interest" or has otherwise established an exemption.
 
  Under current United States federal income tax law, (i) interest payments
(including OID) with respect to a Note collected outside the United States by
a foreign office of a custodian, nominee or broker acting on behalf of a
beneficial owner of a Note, and (ii) payments on the sale or other disposition
of a Note to or through a foreign office of a broker are not generally subject
to backup withholding or information reporting. However, if such custodian,
nominee or broker is a "United States person" (as defined in Section
7701(a)(30) of the Code), a controlled foreign corporation for United States
tax purposes or a foreign person 50% of more of whose gross income is
effectively connected with the conduct of a United States trade or business
for a specified three-year period (a "U.S. Related Person"), such custodian,
nominee or broker may be subject to certain information reporting (but not
backup withholding) requirements with respect to such payments, unless such
custodian, nominee or broker has in its records documentary evidence that the
beneficial owner is not a United States Holder and certain conditions are met
or the beneficial owner otherwise establishes an exemption. Backup withholding
may apply to any payment that such custodian, nominee or broker is required to
report if such person has actual knowledge that the payee is a United States
Holder. Payments to or through the United States office of a broker will be
subject to backup withholding and information reporting unless the Holder
certifies, under penalties of perjury, that it is not a United States Holder
or otherwise establishes an exemption.
 
  The 1997 Final Regulations modify certain of the certification requirements
for backup withholding and expand the group of U.S. Related Persons. It is
possible that the Obligors or their paying agent may request new withholding
exemption forms from Holders in order to qualify for continued exemption from
backup withholding when the 1997 Final Regulations become effective.
 
  Backup withholding tax is not an additional tax. Rather, any amounts
withheld from a payment to a Holder under the backup withholding rules are
allowed as a refund or a credit against such Holder's United States federal
income tax; provided that the required information is furnished to the
Service.
 
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