080305_JPM Series Fix and Win ... - Börse Stuttgart
080305_JPM Series Fix and Win ... - Börse Stuttgart
080305_JPM Series Fix and Win ... - Börse Stuttgart
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A09110530 AF 39<br />
TAXATION<br />
The comments below address only taxation on income from Notes withheld at source <strong>and</strong> a limited number of<br />
other taxation aspects of the Notes in a limited number of jurisdictions <strong>and</strong> are included herein solely for<br />
information purposes. These comments cannot replace legal or tax advice. Holders are advised to consult their<br />
professional advisers on all taxation aspects of an investment in Notes. Holders should be aware that they may<br />
be liable to taxation under the laws of any jurisdiction in relation to payments in respect of the Notes even if<br />
such payments may be made without withholding or deduction for or on account of taxation under the laws of<br />
any of the jurisdictions specified below. No representation with respect to the consequences to any particular<br />
prospective holder of a Note is made hereby. Prospective holders of a Note should consult their own tax advisers<br />
in all relevant jurisdictions.<br />
PROSPECTIVE PURCHASERS OF THE NOTES ARE ADVISED TO CONSULT THEIR OWN ADVISORS<br />
AS TO THE TAX CONSEQUENCES FOR THEM OF A PURCHASE AND HOLDING OF NOTES.<br />
United States Taxation<br />
The comments below address only certain aspects of the taxation of income from Instruments (in the following<br />
sections regarding United States taxation, "Notes" <strong>and</strong> "Instruments" refers to securities issued under the<br />
Programme generally) in a limited number of jurisdictions <strong>and</strong> are included herein solely for information<br />
purposes. These comments cannot replace legal or tax advice.<br />
Instruments may have terms or conditions that result in tax consequences that differ from those described below.<br />
In that case, the supplement pursuant to which those Instruments are issued will include a summary of material<br />
tax considerations applicable to those Instruments.<br />
PROSPECTIVE PURCHASERS OF THE INSTRUMENTS ARE ADVISED TO CONSULT THEIR OWN<br />
ADVISORS AS TO THE TAX CONSEQUENCES TO THEM OF THE PURCHASE, OWNERSHIP AND<br />
DISPOSITION OF AN INSTRUMENT.<br />
United States Federal Income Taxation<br />
The following is a summary of certain United States federal income <strong>and</strong> estate tax consequences of the<br />
purchase, ownership <strong>and</strong> disposition of Instruments. This summary is based on the Internal Revenue Code of<br />
1986, as amended to the date hereof (the "Code"), administrative pronouncements, judicial decisions <strong>and</strong><br />
existing, proposed <strong>and</strong> temporary Treasury Regulations, changes to any of which subsequent to the date hereof<br />
may affect the tax consequences described herein.<br />
This summary discusses only the principal United States federal income tax consequences to United States<br />
Alien Holders (as defined below). It does not address all of the tax consequences that may be relevant to a<br />
Holder in light of the Holder's particular circumstances. The Instruments are not intended to be held by United<br />
States Persons <strong>and</strong> a holder of a bearer Instrument that is treated as a debt obligation for U.S. federal income tax<br />
purposes who is a United States Person will be subject to the limitations under U.S. income tax laws, including<br />
the limitations provided in Sections 165(j) <strong>and</strong> 1287(a) of the Code.<br />
For purposes of the discussion below, a "United States Alien" means a person that for U.S. federal income tax<br />
purposes is (i) a foreign corporation, (ii) a non-resident alien individual that is not a U.S. citizen or (iii) a foreign<br />
estate or trust.<br />
This discussion is limited to the federal tax issues addressed herein. Additional issues may exist that are not<br />
addressed in this discussion <strong>and</strong> that could affect the federal tax treatment of an investment in the Notes. This<br />
tax disclosure was written to support the dissemination of this Prospectus, <strong>and</strong> it cannot be used by any holder<br />
for the purpose of avoiding penalties that may be asserted against the holder under the Internal Revenue Code.<br />
Holders should seek their own advice based on their particular circumstances from an independent tax adviser.