08.10.2013 Aufrufe

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.

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