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unsel, Davis Polk & Wardwell LLP, has advised that it believes this treatment to be reasonable, but that there are other reasonable treatments that the Internal Revenue Service (the "IRS") or a court may adopt. Sale, Exchange or Redemption of a Note. Assuming the treatment described above is respected, upon a sale or exchan
. 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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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
on, the entire amount received will be treated as a distribution and will be taxable as described under the caption " aaxation of Dividends" above. Non-U.S. Holders The following discussion is a summary of certain United States federal tax consequences that will apply to you if you are a non-U.S. Holder of depo
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mmary 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, all as in effect on the date of this Memorandum and all of which are subject to change
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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mmary 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, all as in effect on the date of this Memorandum and all of which are subject to change
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 (10)
Entities connected to both the Internal Revenue Service and Non-U.S. Holders
JPMorgan Chase
ORGANIZATION754 w/ the·2 w/ Non-U.S.
United States
LOCATION124 w/ the·2 w/ Non-U.S.
the Securities and Exchange Commission
ORGANIZATION50 w/ the·3 w/ Non-U.S.
Eric Holder
PERSON46 w/ the·5 w/ Non-U.S.
U.S. Treasury
ORGANIZATION38 w/ the·3 w/ Non-U.S.
United Kingdom
LOCATION21 w/ the·2 w/ Non-U.S.
U.S. Department
ORGANIZATION7 w/ the·2 w/ Non-U.S.
the New York Banking Law
ORGANIZATION2 w/ the·2 w/ Non-U.S.
The Onshore Feeder Fund's
ORGANIZATION2 w/ the·2 w/ Non-U.S.
Offshore Feeder Fund
ORGANIZATION2 w/ the·2 w/ Non-U.S.