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

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

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

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

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

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

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

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

come in their home jurisdiction and, depending on the tax rules of their home jurisdiction, may be entitled to claim either a credit (in the case of U.S. Holders, subject, however, to various limitations on foreign tax credits, as discussed above under "Foreign Tax Credit Limitations") or a deduction (in the

ult for U.S. Holders that are not tax-exempt persons that own an interest in the Offshore Feeder Fund, including Investors that subsequently become U.S. Holders after their initial investment in the Offshore Feeder Fund. Such Investors should consult their own tax advisors as to the U.S. tax implications to