Untitled - Irish Stock Exchange

intends to treat the Income Notes as equity interests in the Issuer for
U.S. federal income tax purposes.
For a discussion of certain U.S. and Irish tax consequences to
investors in Notes, see "Income Tax Considerations" herein.
ERISA Considerations ................................ Subject to certain conditions as described in "ERISA
Considerations," the Class B Notes, the Class C Notes and the Class
D Notes may generally be acquired by pension, profit sharing or
other retirement plans and accounts subject to Title I of ERISA or
Section 4975 of the Code, and by entities that are deemed to hold
assets of any of the foregoing. The Class E Notes and the Income
Notes may not be acquired by any such plans or entities. See
"ERISA Considerations" herein for a more detailed discussion of
certain ERISA and related considerations with respect to an
investment in the Notes.
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