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JPMORGAN CHASE & CO. - Irish Stock Exchange

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For purposes of determining the amount of OID subject to these rules, all interest payments on a Short- Term Registered<br />

Note are included in the Short-Term Registered Note's stated redemption price at maturity. A U.S. Holder may elect to<br />

determine OID on a Short-Term Registered Note as if the Short-Term Registered Note had been originally issued to the<br />

U.S. Holder at the U.S. Holder's purchase price for the Short-Term Registered Note. This election shall apply to all<br />

obligations with a maturity of one year or less acquired by the U.S. Holder on or after the first day of the first taxable<br />

year to which the election applies, and may not be revoked without the consent of the IRS.<br />

Contingent Payment Debt Instruments<br />

Certain Series or Tranches of Registered Notes may be treated as contingent payment debt instruments ("Contingent<br />

Registered Notes") for U.S. federal income tax purposes. Under applicable U.S. Treasury regulations, interest on the<br />

Contingent Registered Notes will be treated as OID and must be accrued on a constant-yield basis based on a yield to<br />

maturity that reflects the rate at which the Issuer would issue a comparable fixed-rate non-exchangeable instrument (the<br />

"comparable yield"), in accordance with a projected payment schedule. This projected payment schedule must include<br />

each non-contingent payment on the Contingent Registered Note and an estimated amount for each contingent payment,<br />

and must produce the comparable yield. Interest inclusions will be adjusted upward and downward to reflect the<br />

difference, if any, between the actual payments received and the projected amount of such payments on the Contingent<br />

Registered Notes under the projected payment schedule. Special rules apply to the sale or other disposition of a<br />

Contingent Registered Note. See "Purchase, Sale and Retirement of Notes" below. The relevant Final Terms or any<br />

Prospectus or series prospectus will indicate the Issuer's intention to treat a particular Series or Tranche of Notes as<br />

Contingent Registered Notes.<br />

The Issuer is required to provide to holders, solely for U.S. federal income tax purposes, a schedule of the projected<br />

amounts of payments on Contingent Registered Notes. This schedule must produce the comparable yield. The<br />

applicable Final Terms or any Prospectus or series prospectus may contain the comparable yield and projected payment<br />

schedule; otherwise a U.S. Holder of a Contingent Registered Note can submit a written request for the schedule to the<br />

attention of Head of FIDM, J.P. Morgan Securities Inc., 270 Park Avenue, New York, New York 10017, unless the<br />

applicable Final Terms or any Prospectus or series prospectus provides a different address for submitting requests for<br />

this information.<br />

THE <strong>CO</strong>MPARABLE YIELD AND PROJECTED PAYMENT SCHEDULE WILL NOT BE DETERMINED FOR<br />

ANY PURPOSE OTHER THAN FOR THE DETERMINATION OF INTEREST ACCRUALS AND ADJUSTMENTS<br />

THEREOF IN RESPECT OF <strong>CO</strong>NTINGENT REGISTERED NOTES FOR UNITED STATES FEDERAL IN<strong>CO</strong>ME<br />

TAX PURPOSES AND WILL NOT <strong>CO</strong>NSTITUTE A PROJECTION OR REPRESENTATION REGARDING THE<br />

ACTUAL AMOUNTS PAYABLE TO THE HOLDERS OF THE REGISTERED NOTES.<br />

The use of the comparable yield and the calculation of the projected payment schedule will be based upon a number of<br />

assumptions and estimates and will not be a prediction, representation or guarantee of the actual amounts of interest that<br />

may be paid to a U.S. Holder or the actual yield of the Contingent Registered Notes. A U.S. Holder will generally be<br />

bound by the comparable yield and the projected payment schedule determined by the Issuer unless the U.S. Holder<br />

determines its own comparable yield and projected payment schedule and explicitly discloses such schedule to the IRS,<br />

and explains to the IRS the reason for preparing its own schedule. The Issuer's determination, however, is not binding<br />

on the IRS, and it is possible that the IRS could conclude that some other comparable yield or projected payment<br />

schedule should be used instead.<br />

A U.S. Holder of a Contingent Registered Note will generally be required to include OID in income pursuant to the<br />

rules discussed in the third paragraph under "Original Issue Discount – General," above. For these purposes, the<br />

"adjusted issue price" of a Contingent Registered Note at the beginning of any accrual period is the issue price of the<br />

Note increased by the amount of accrued OID for each prior accrual period, and decreased by the projected amount of<br />

any payments made on the Note. No additional income will be recognised upon the receipt of payments of stated interest<br />

80

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