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a court may adopt, in which case the timing and character of any income or loss on the Notes could be materially affected. In addition, in 2007 the U.S. Treasury Department and the IRS released a notice requesting comments on the U.S. federal income tax treatment of "prepaid forward contracts" and similar instruments.
. federal income tax consequences of an investment in the Notes, including possible alternative treatments and the issues presented by this notice. Non-U.S. Holders. Insofar as we have responsibility as a withholding agent, we do not currently intend to treat Contingent Coupon payments to non-U.S. holders (as de
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(as defined herein) who purchase their respective interests in the offering. This summary is based upon the Code, U.S. Department of the Treasury ("U.S. Treasury Department") regulations promulgated thereunder, published rulings of the Internal Revenue Service (the "IRS"), court decisions and other applicable authority
e Feeder Fund by U.S. Holders (as defined herein) and of Interests in the Offshore Feeder Fund by U.S. Tax-Exempt Investors (as defined herein) and Non-U.S. Holders (as defined herein) who purchase their respective interests in the offering. This summary is based upon the Code, U.S. Department of the Treasury (
2 mentions1 same-page
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(as defined herein) who purchase their respective interests in the offering. This summary is based upon the Code, U.S. Department of the Treasury ("U.S. Treasury Department") regulations promulgated thereunder, published rulings of the Internal Revenue Service (the "IRS"), court decisions and other applicable authority
e Feeder Fund by U.S. Holders (as defined herein) and of Interests in the Offshore Feeder Fund by U.S. Tax-Exempt Investors (as defined herein) and Non-U.S. Holders (as defined herein) who purchase their respective interests in the offering. This summary is based upon the Code, U.S. Department of the Treasury (
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Mutual Connections (9)
Entities connected to both U.S. Treasury and Non-U.S. Holders
United States
LOCATION197 w/ U.S.·2 w/ Non-U.S.
United Kingdom
LOCATION53 w/ U.S.·2 w/ Non-U.S.
the Internal Revenue Service
ORGANIZATION38 w/ U.S.·4 w/ Non-U.S.
the Securities and Exchange Commission
ORGANIZATION35 w/ U.S.·3 w/ Non-U.S.
JPMorgan Chase
ORGANIZATION31 w/ U.S.·2 w/ Non-U.S.
Eric Holder
PERSON22 w/ U.S.·5 w/ Non-U.S.
U.S. Department
ORGANIZATION4 w/ U.S.·2 w/ Non-U.S.
The Onshore Feeder Fund's
ORGANIZATION2 w/ U.S.·2 w/ Non-U.S.
Offshore Feeder Fund
ORGANIZATION2 w/ U.S.·2 w/ Non-U.S.