Epstein Secrets

rities plc. a subsidiary of JPMorgan Chase Bank. N.A. The prin " ce of JPMorgan Chase is located at 270 Park Avenue. New York. New York 10017-2070, U.S.A.. and its telephone number i S-9 EFTA00601712 Table of Contents WHERE YOU CAN FIND MORE INFORMATION ABOUT JPMORGAN CHASE We file annual, quar

y deals only with depositary shares purchased in this offering and held as capital assets. This summary does not represent a detailed description of the United States federal income tax consequences applicable to you if you are subject to special treatment under the United States federal income tax laws. including

o you in light of your particular circumstances and does not address the Medicare tax on net investment income or the effects of any state, local or non-United States tax laws. If you are considering the purchase, ownership or disposition of depositary shares, you should consult your own tax advisors concerning th

ied. Instead, such dividends are subject to United States federal income tax on a net income basis in the same manner as if the non-U.S. Holder were a United States person as defined under the Internal Revenue Code. Any such effectively connected dividends received by a foreign corporation may be subject to an a

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

transaction for tax purposes; • a United States holder (as defined below) whose functional currency for tax purposes is not the U.S. dollar; • a United State expatriate; or • a person liable for alternative minimum tax. This section is based on the United States Internal Revenue Code of 1986. as amended

agency or instrumentality of the United States, including the FRB and other federal bank regulatory agencies) or any political subdivision of or in the United States that is enacted or becomes effective after the initial issuance of any share of the Series F Preferred Stock, (ii) any proposed change in those laws

erson and you have furnished a valid IRS Form W-8 or other documentation upon which the payor or broker may rely to treat the payments as made to a non-United States person, or (ii) you othenvise establish an exemption. Payment of the proceeds from the sale of Series F Preferred Stock effected at a foreign office

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 "

SUBJECT TO THE GENERAL PARTNER'S ABILITY TO REJECT ANY COMMITMENT IN WHOLE OR IN PART. THE INTERESTS HAVE NOT BEEN AND WILL NOT BE REGISTERED UNDER THE UNITED STATES SECURITIES ACT OF 1933, AS AMENDED (THE "SECURITIES ACT), OR ANY UNITED STATES STATE SECURITIES LAWS OR THE LAWS OF ANY FOREIGN JURISDICTION. THE I

ary income on all or a portion of the gain from the sale of stock of a CFC. INVESTMENT BY THE PARTNERSHIP IN PASSIVE FOREIGN INVESTMENT COMPANIES. A non-United States corporation in which the Partnership invests may be classified as a passive foreign investment company ("PFJC') in one or more taxable years while t

Alternative Investment Fund Managers Directive ("AIFMD") came into force on 21 July 2011, and certain fund managers have been obliged to comply with the European Economic Area ("EEA") Member States' respective AIFMD implementing laws since July 22, 2013. AIFMD regulates the activities of private fund managers undertaking

iodical income received from sources within the United States if such income is not treated as effectively connected with a trade or business within the United States. The 30% rate may be reduced or eliminated under the provisions of an applicable income tax treaty between the United States and the country in whic

nder should qualify as a -publicly offered security" within the meaning of the Plan Asset Regulations. Governmental plans, certain church plans and non-United States plans (each, a "Non-ERISA Plan"), while not subject to the fiduciary responsibility or prohibited transaction provisions of Title I of ERISA or Sec

Act, or to contribute to payments the underwriters may be required to make because of any of those liabilities. Notice to Prospective Investors in the European Economic Area In relation to each member state of the European Economic Area (each, a relevant member state), with effect from and including the date on which th

e appointed within 60 days after delivery of the notice of resignation or removal and must be a bank or trust company having its principal office in the United States and having a combined capital and surplus of at least $50,000,000. Miscellaneous The depositary will forward to the holders of depositary shares al

uld consult their own advisor. Notice to Prospective Investors in Certain Jurisdictions European Economic Area In relation to each Member State of the European Economic Area which has implemented the Prospectus Directive (each, a "Relevant Member State"), with effect from and including the date on which the Prospectus D

hases, the definition of a U.S. Person is: 1) any resident of the United States; 2) any partnership or corporation organized in or under the laws of the United States; 3) any estate or trust in which the executor, administrator or trustee is a U.S. person and/or if the income from the estate or trust is subject to

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