Epstein Secrets

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

es owned by such holders, when, as and if declared by the Board of Directors of the Company. In the event of a distribution other than in cash, the Depositary will distribute property received by it to the record holders of Depositary Shares entitled thereto. If the Depositary determines that it is not fea

ckup withholding rules, 31% of the gross proceeds payable to a stockholder or ot=er payee pursuant to the Offer must be withheld and remitted to the United Sta=es Treasury, unless the stockholder or other payee provides his or her taxpaye= identification number (employer identification number or social sec

to their customers. 16. Miscellaneous. The Offer is not being made to, nor will the Company accept tenders from, holders of Shares in any state of the United States or any foreign jurisdiction in which the Offer or the acceptance thereof would not be in compliance with the laws of such state or foreign jurisdict

ovided below) by the Expiration Date; and (iii) the certificates for such Shares (or a confirmation of a book-entry transfer of such Shares into the Depositary's account at the Book- Entry Transfer Facility), together with a properly completed and duly executed Letter of Transmittal (or facsimile thereof)

e term "U.S. holder" means a beneficial owner of a Note that is: • an individual who is a citizen of the United States or who is a resident alien of the United States for U.S. federal income tax purposes; S-23 EFTA00690313 • a corporation or other entity taxable for U.S. federal income tax purposes as a corpora

cial interests in such Global Security will be shown on, and the transfer of that ownership will be effected only through, records maintained by the Depositary or its nominee (with respect to interests of its participants), and on the records of its participants (with respect to interests of persons other t

ension fund" is any trust, corporation, or other organization or arrangement (A) which is created or organized under the law of a country other than the United States, (B) which is established to provide retirement or pension benefits to participants or beneficiaries that are S-16 EFTA00595864 current or former

ccounts. In certain circumstances, the Preferred Shares Depositary may refuse to transfer Depositary Shares. may withhold distributions and sell the Depositary, Shares evidenced by such Depositary Receipt if such charges are not paid. Miscellaneous The Preferred Shares Depositary will forward to the holde