United States federal tax consequences that will apply to you if you are a non-U.S. Holder of depositary shares. Special rules may apply to certain non-U.S. Holders, such as " controlled foreign corporations: " passive foreign investment companies: and certain expatriates, among others, that are subject to speci

s of United States federal income and estate taxius and does not deal with foreign, slate, local or other tax considerations that may be relevant to non-U.S. Holders in light of their personal circumstances, including the impact of the alternative minimum tax and the Medicare contribution tax on net investment in

relevant certification requirements of applicable United States Treasurys regulations. Special certification and other requirements apply to certain non-U.S. Holders that are pass-through entities rather than corporations or individuals. A non-U.S. Holder of our common stock eligible for a reduced rate of United