o a Non-U.S. Holder (as defined in the accompanying product supplement) of the securities as subject to U.S. federal withholding tax, provided that the Non-U.S. Holder complies with applicable certification requirements. However, it is possible that the IRS could assert that such payments are subject to U.S. withho

(iii) the certification requirements described below are satisfied. The certification requirements referred to above generally will be satisfied if the Non-U.S. Holder provides the applicable withholding agent with a statement (generally on IRS Form or W-BEN or W-8BEN-E), signed under penalties of perjury, stating

of an interest, unless (i) the distributions or gains on the interest are attributable to an office or other fixed place of business maintained by the Non-U.S. Holder in the United States, (ii) in the case of gain realized, the Non-U.S. Holder is a non-resident alien individual who is present in the United States