JPMORGAN CHASE & CO. - Irish Stock Exchange

(d)
A beneficial owner of a Bearer Note or coupon that is a Non-U.S. Holder will not be required to disclose its
nationality, residence, or identity to the Issuer, a paying agent, or any U.S. governmental authority in order to
receive payment on the Note or coupon from the Issuer or a paying agent outside the United States (although
the beneficial owner of an interest in the temporary Global Note will be required to provide a Certificate of
Non-U.S. Beneficial Ownership in order to receive a beneficial interest in a Permanent Global Note or
definitive Notes and coupons and interest thereon).
For purposes of this discussion, "Non-U.S. Holder" means any corporation, partnership, individual or estate or trust
that, for U.S. federal income tax purposes, is (i) a foreign corporation, (ii) a foreign partnership all of whose partners are
Non-U.S. Holders, (iii) a non-resident alien individual or (iv) a foreign estate or trust all of whose beneficiaries are Non-
U.S. Holders.
For purposes of this discussion, “payments of principal, premium, and interest” mean payments made with respect to
Notes or Coupons that are treated as payments of principal, premium, OID, and interest for U.S. federal income tax
purposes. However, as discussed above, the proper characterisation of the Notes for federal income tax purposes is
uncertain. It is possible that payments made with respect to certain of the Notes, including in particular certain Index
Linked Redemption Notes, Credit Linked Notes and Equity Linked Notes, may not be treated as payments of principal,
premium, OID or interest for these purposes. Although the Issuer expects that payments made with respect to Notes
should not be subject to U.S. withholding tax (assuming all parties comply with the terms of the Programme, any
Prospectus or series prospectus and/or the applicable Final Terms, and any documents incorporated by reference) and
does not currently expect that withholding agents generally will withhold on payments under the Notes, it can provide
no assurance that withholding on payments under certain of the Notes, it can provide no assurance that withholding on
payments under the Notes will not be imposed. If the Issuer determines that withholding is appropriate with respect to
payments on a particular Note, the Issuer will so indicate in the applicable Final Terms or any Prospectus or series
prospectus. The Issuer (and its paying agents) reserves the right to make any withholding they determine is required by
applicable law.
Backup Withholding and Information Reporting
Unless the relevant Issuer or the paying agent has actual knowledge or reason to know that the holder or beneficial
owner, as the case may be, is a U.S. person (as defined in the Code), payments of principal, OID, and interest on Notes
made to a Non-U.S. Holder will not be subject to backup withholding, provided the Non-U.S. Holder provides the payer
with an IRS Form W-8, but interest and OID paid on Notes with a maturity of more than 183 days will be reported to
the IRS as required under applicable regulations.
Payments of principal, OID and interest on Bearer Notes made outside the United States to a Non-U.S. Holder by a non-
U.S. payor will not be subject to information reporting and backup withholding.
In addition, except as provided in the following sentence, if principal, OID or interest payments made with respect to
Bearer Notes are collected outside the United States on behalf of a beneficial owner of a Bearer Note by a foreign office
of a custodian, nominee or other agent who is not a U.S. Controlled Person, (as defined below), the custodian, nominee
or other agent will not be required to apply backup withholding to these payments when remitted to the beneficial owner
and will not be subject to information reporting. However, if the custodian, nominee or other agent is a U.S. Controlled
Person, payments collected by its United States or foreign office may be subject to information reporting and backup
withholding unless the custodian, nominee or other agent has in its records documentary evidence that the beneficial
owner is not a U.S. person or is otherwise exempt from information reporting, and it has no actual knowledge or reason
to know that any of the information or certifications associated with this documentation is incorrect.
Payments on the sale, exchange or other disposition of a Bearer Note made to or through a foreign office of a broker
will generally not be subject to information reporting or backup withholding. However, if the broker is a U.S. Controlled
Person, payments on the sale, exchange or other disposition of the Bearer Note made to or through a United States or
foreign office of the broker will be subject to information reporting unless the beneficial owner has furnished the broker
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