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New York Mellon will act as depositary for each of Cleargrerun and Euroclear. Clearstream has advised us that it is incorporated under the laws of Luxembourg as a professional depositary. Clearstream holds securities for its participants and facilitates the clearance and settlement of securities transacti
States permanent establishment) are not subject to the withholding tax, provided certain certification and disclosure requirements (generally on an Internal Revenue Service (" IRS" ) Form W-8ECI) are satisfied. Instead, such dividends are subject to United States federal income tax on a net income basis in the same mann
o the transfer agent in accordance with their respective customary procedures. Clearstream has advised us that it is incorporated under the laws of Luxembourg as a professional depositary. Clearstream holds securities for its participants and facilitates the clearance and settlement of securities transact
ired to withhold at a 30% rate (rather than the lower treaty rate) on dividend payments to you, unless you have furnished to such payor: • a valid Internal Revenue Service Form W-8BEN or W-8BEN-E, or an acceptable substitute form upon which you certify, under penalties of perjury, your status as a person who is not a U
or omissions of, or any inaccuracies in the records of, any non-Affiliated custodian, clearing agency, common depository, Euroclear or Clearstream, Luxembourg or for the acts or omissions of the Collateral Manager or either Co-Issuer; and 108 EFTA00596240 (1) the enumeration of any permissible rights
. federal income tax purposes and (ii) a "PFIC Annual Information Statement" as described in Treasury Regulation Section 1.1295-1 (or any successor Internal Revenue Service release or Treasury Regulation), including all representations and statements required by such statement, and will take any other reasonable steps
Entities connected to both Luxembourg and Internal Revenue Service

Jeffrey Epstein
PERSON
Belgium
LOCATION
Finland
LOCATION
Denmark
LOCATION
United States
LOCATION
Estonia
LOCATION
George W. Bush
PERSON
U.S. Treasury
ORGANIZATION
New Zealand
LOCATION
Samantha Power
PERSON
Marc Rich
PERSON
Ghislaine Maxwell
PERSON
New York
LOCATION
Prince Charles
PERSON
Donald Trump
PERSON
Eric Holder
PERSON
Department of Justice
ORGANIZATION
Terje Rod-Larsen
PERSON
Prince Andrew
PERSONLeon Black
PERSON