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

also will be given by mail to the addresses of the holders as they appear on the security register. S-28 EFTA00601731 Table of Contents CERTAIN UNITED STATES FEDERAL INCOME TAX CONSIDERATIONS The following is a summary of certain United States federal tax consequences of the purchase. ownership and disposition of depositary shares repres

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

elieves to be reliable, but The Bank of New York Mellon Corporation takes no responsibility for the accuracy thereof. S-29 EFTA00597138 MATERIAL UNITED STATES FEDERAL INCOME TAX CONSIDERATIONS This section describes the material United States federal income tax consequences relevant to the purchase, ownership and disposition of the Series

VCs are not stock in the Issuer. However, no assurances can be given in this regard, and it is possible that a U.S. Holder of SVCs may be treated as a United States Shareholder. If the SVCs were treated as stock in the Issuer and the Issuer were treated as a CFC, a U.S. Holder of SVCs that is treated as a Unite

NGS 48 DATA PROTECTION 48 CERTAIN BRITISH VIRGIN ISLANDS TAXATION CONSIDERATIONS 49 CERTAIN CAYMAN ISLANDS TAXATION CONSIDERATIONS 51 CERTAIN UNITED STATES FEDERAL INCOME TAX CONSIDERATIONS FOR U.S. HOLDERS 53 RISK FACTORS 56 RESALE AND TRANSFER RESTRICTIONS 75 NOTICE TO PURCHASERS 76 TO PURCHASERS GENERALLY 78 EXHIBIT A - FORM

ed as trusts for U.S. federal income tax purposes are subject to special rules). If the Fund is not engaged in the conduct of a trade or business in the United States, Non-U.S. Partners in the Fund's shares of income and gains from sources other than the United States (e.g., generally, interest or dividends paid b

THE ADMINISTRATOR 18 NET ASSET VALUE 19 LEGAL PROCEEDINGS 20 DATA PROTECTION 20 CERTAIN CAYMAN ISLANDS TAXATION CONSIDERATIONS 21 CERTAIN UNITED STATES FEDERAL INCOME TAX CONSIDERATIONS 23 RISK FACTORS 29 REGULATION 39 ANTI-MONEY LAUNDERING AND ANTI-TERRORIST FINANCING PROCEDURES 40 NOTICE TO PURCHASERS 42 WEST1282936389.4