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ax reported on the Consolidated Financial Statements will not be adjusted by either adverse rulings, changes in the tax code, or assessments made by the Internal Revenue Service, state, or foreign taxing authorities. The Company is subject to potential adverse adjustments, including but not limited to: an increase in the sta
iscussed in this report and in the Company's Form 10-K for the year ended March 31, 2018 , including, but not limited to, any discussions in Part I, Item IA, "Risk Factors" (as supplemented by any subsequent disclosures in information the Company files with or furnishes to the SEC from time to time), man
date of the debentures, the debentures will be treated as indebtedness for U.S. federal income tax purposes. However, there can be no assurance that the Internal Revenue Service ("IRS") or a court will agree with our determination. No ruling is being sought from the IRS on any of the issues discussed herein. S-24 EFTA_R1_0
and the applicable prospectus supplement. You should consider the risks, uncertainties and assumptions discussed under the caption "Risk Factors" in Item IA of our Annual Report, which is incorporated by reference in this prospectus. If any of the events or circumstances described as risks actually occur
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
any of our securities, in addition to the other information in this prospectus, you should carefully consider the risk factors contained in Part I, Item IA under the caption "Risk Factors" in our Annual Report on Form 10-K for the fiscal year ended December 31, 2014 and in our 2014 Annual Report to Sha
Entities connected to both the Internal Revenue Service and Item IA
the State of New York
LOCATION
United States
LOCATIONthe Securities and Exchange Commission
ORGANIZATION
New York
LOCATION
Eric Holder
PERSONthe District of Columbia
LOCATION
United Kingdom
LOCATION
the Board of Directors
ORGANIZATION
Ontario
LOCATION
Morgan Stanley
ORGANIZATIONIndebtedness
ORGANIZATION
Exchange
ORGANIZATION
Bermuda
LOCATIONMorgan Stanley & Co. LLC
ORGANIZATIONEuroclear
ORGANIZATIONRegistrar
ORGANIZATIONThe Bank of New York Mellon
ORGANIZATIONthe European Economic Area
LOCATIONPierce, Fenner & Smith Incorporated
ORGANIZATIONthe City of New York
LOCATION