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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
it for securities similar to the debentures. The rating agencies that currently publish a rating for us, including Moody's Investors Service, Inc., Standard & Poor's Ratings Services, a Standard & Poor's Financial Services LLC business, and A.M. Best Company, Inc., may, from time to time in the future, change the way they analyze
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
a whole. For example, in March 2015, Moody's Investors Service published its revised methodology for rating banks globally, and, in December 2015, Standard & Poor's Ratings Services ("M") removed the government support assumptions on the eight U.S. global systemically important banks, including us, which resulted in a one- notch
e not required to make gross-up payments that cover the full amount of such withholding taxes on an after-tax basis or (ii) a final determination by the Internal Revenue Service or a court of competent jurisdiction or an opinion of nationally recognized tax counsel experienced in such matters acceptable to the Collateral Ma
obal Security": The meaning specified in Section 2.2(c). "Rule 144A Information": The meaning specified in Section 7.15. "M' or "Standard & Poor's: Standard & Poor's Ratings Services, a division of The McGraw-Hill Companies, Inc., and any successor or successors thereto. CDO Monitor": A dynamic, analytical computer program devel
Entities connected to both the Internal Revenue Service and Standard & Poor's Ratings Services

Jeffrey Epstein
PERSONthe State of New York
LOCATION
Federal Reserve
ORGANIZATION
United States
LOCATIONLeon Black
PERSON
Samantha Power
PERSONthe District of Columbia
LOCATIONthe Securities and Exchange Commission
ORGANIZATION
Eric Holder
PERSON
New York
LOCATION
European Union
ORGANIZATION
United Kingdom
LOCATION
Credit Suisse
ORGANIZATION
Cayman Islands
LOCATIONCayman
LOCATIONKeogh
ORGANIZATION
Ontario
LOCATION
Luxembourg
LOCATION
Morgan Stanley
ORGANIZATIONthe New York Stock Exchange
ORGANIZATION