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

been met. stock considered to be owned by a U.S. Holder by reason of certain constructive ownership rules, as well as shares actually owned by such U.S. Holder. must generally be taken into account. If a particular U.S. Holder of depositary shares does not own (actually or constructively) any additional sto

poses of this summary, a "U.S. Holder" is a beneficial owner of an Interest that is, for U.S. federal income tax purposes, a citizen or resident of the United States, a U.S. domestic corporation or otherwise subject to U.S. federal income tax on a net income basis with respect to its Interest. A "Non-U.S. Holder

erwise subject to U.S. federal income tax on a net income basis with respect to its Interest. A "Non-U.S. Holder" means any Investor that is not a U.S. Holder. II CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0108140 CONFIDENTIAL SONY GM_00254324 EFTA01451506

ad, such dividends arc subject to United States federal income tax on a net income basis generally in the same manner as if the non- U.S. Holder were a United States person as defined under the Code. Any such effectively connected dividends receives' by a foreign corporation may be subject to an additional "branc

satisfied. Instead, such dividends arc subject to United States federal income tax on a net income basis generally in the same manner as if the non- U.S. Holder were a United States person as defined under the Code. Any such effectively connected dividends receives' by a foreign corporation may be subject to

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

ment of the Issuance of SVCs The Issuer intends to treat the issuance of SVCs to a U.S. Holder as a purchase of property (that is, the SVCs) by the U.S. Holder. The Issuer intends to treat SVCs neither as equity interests nor as debt interests in the Issuer for U.S. federal income tax purposes. A U.S. Holde