Epstein Secrets

had not occurred. That opinion, in the case of defeasance but not covenant defeasance. must refer to and be based upon a ruling received by us from the Internal Revenue Service or published as a revenue ruling or be based upon a change in applicable federal income tax law. If we exercise our covenant defeasance option with

s represented to us and agreed with us that it has not made and will not make an offer of the depositary shares to the public in any member state of the European Economic Area which has implemented the Prospectus Directive (a" Relevant Member State" ) from and including the date on which the Prospectus Directive is impleme

y may obtain a refund of any amounts withheld under the backup withholding rules that exceed your income tax liability by filing a refund claim with the Internal Revenue Service. THE PRECEDING DISCUSSION OF THE MATERIAL UNITED STATES FEDERAL INCOME TAX CONSEQUENCES IS FOR GENERAL INFORMATION PURPOSES ONLY AND IS NOT BEING

NI 33-105 regarding underwriter conflicts of interest in connection with this offering. European Economic Area In relation to each Member State of the European Economic Area (each, a "Member State"), each underwriter from and including the date on which the Prospectus Directive is implemented in that Member State (the "

e and absolute discretion. If you are an individual (including an individual acting as trustee of a trust) residing in or located in any country in the European Economic Area: you represent and warrant that you do not intend to use any part of a margin loan, and will not now or in the future use any part of a margin loan

be issued to me), and 2)1 am not subject to backup withholding because: (a) I am exempt from backup withholding, or (b) I have not been notified by the Internal Revenue Service (IRS) that I am subject to backup withholding as a result of a failure to report all interest and dividends, or (c) the IRS has notified me that lam