Epstein Secrets

ction 988 of the Code. Although not clear, a U.S. Holder (as defined in the accompanying prospectus suppl

the reach of the revenue ruling were to be extended, it could materially and adversely affect the tax consequences of an investment in the Notes for U.S. Holders, possibly with retroactive effect. h ttp.//www.sec.gov/Archives/edgar/data/83246/000114420413020645/v340782_424b2.htm 10/29/2013 CONFIDENTIAL - PU

ction 988 of the Code. Although not clear, a U.S. Holder (as defined in the accompanying prospectus suppl

the reach of the revenue ruling were to be extended, it could materially and adversely affect the tax consequences of an investment in the Notes for U.S. Holders, possibly with retroactive effect. h ttp.//www.sec.gov/Archives/edgar/data/83246/000114420413020645/v340782_424b2.htm 10/29/2013 CONFIDENTIAL - PU

ion 988 of the Code. Although not clear, a U.S. Holder (as defined in the accompanying EFTA01465584 p

he reach of the revenue ruling were to be extended, it could materially and adversely affect the tax consequences of an investment in the Notes for U.S. Holders, possibly with retroactive effect. EFTA01465585 Withholding and reporting requirements under the legislation enacted on March 18, 2010 (as discus

tion 988 of the Code. Although not clear, a U.S. Holder (as defined in the accompanying prospectus suppl

revenue ruling were to be extended, it could EFTA01465559 materially and adversely affect the tax consequences of an investment in the Notes for U.S. Holders, possibly with retroactive effect. http://www.sec.gov/Archives/edgar/data/83246/000114420413020645/- v340782 424b2.htm 10/29/2013 EFTA01465560 P

ws. For purposes of this summary, the term "U.S. Holder" means a beneficial owner of Shares that, for US.

tal gain or loss if a U.S. Holder's holding period for such Shares is more than one year. Long- term capital gain recognized by certain non-corporate U.S. Holders, including individuals, is generally subject to U.S. federal income tax at preferential rates. The deductibility of a capital loss recognized pursua

ws. For purposes of this summary, the term "U.S. Holder" means a beneficial owner of Shares that, for US.

tal gain or loss if a U.S. Holder's holding period for such Shares is more than one year. Long- term capital gain recognized by certain non-corporate U.S. Holders, including individuals, is generally subject to U.S. federal income tax at preferential rates. The deductibility of a capital loss recognized pursua

ing tax will apply to those payments if such U.S. Holder fails to provide certain identifying information

their tax advisers regarding their information reporting obligations with respect to their ownership of Preferred Shares. FBAR (FinCEN Repoli 114). U.S. Holders, and non-U.S. Holders with certain minimum contacts with the United States, of Preferred Shares may be required to report certain information on Uni

ws. For purposes of this summary, the term "U.S. Holder" means a beneficial owner of Shares that, for US.

tal gain or loss if a U.S. Holder's holding period for such Shares is more than one year. Long- term capital gain recognized by certain non-corporate U.S. Holders, including individuals, is generally subject to U.S. federal income tax at preferential rates. The deductibility of a capital loss recognized pursua