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ction 988 of the Code. Although not clear, a U.S. Holder (as defined in the accompanying prospectus suppl
to the limitations described therein, and based on certain factual representations received from us, in the opinion of our special U.S. tax counsel, Morrison & Foerster LLP, it is reasonable to treat a Note as a pre-paid executory contract with respect to the Reference Currency. Assuming this characterization is respect
ction 988 of the Code. Although not clear, a U.S. Holder (as defined in the accompanying prospectus suppl
to the limitations described therein, and based on certain factual representations received from us, in the opinion of our special U.S. tax counsel, Morrison & Foerster LLP, it is reasonable to treat a Note as a pre-paid executory contract with respect to the Reference Currency. Assuming this characterization is respect
tion 988 of the Code. Although not clear, a U.S. Holder (as defined in the accompanying prospectus suppl
the limitations described therein, and based on certain factual representations received from us, in the opinion of our special U.S. tax counsel, Morrison & Foerster LLP, it is reasonable to treat a Note as a pre-paid executory contract with respect to the Reference Currency. Assuming this characterization is respec
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ORGANIZATIONU.S. Holders
ORGANIZATIONthe City of New York
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