JPMORGAN CHASE & CO. - Irish Stock Exchange

with documentation upon which the broker can rely to treat the payment as made to a beneficial owner that is a foreign
person, and the broker has no actual knowledge or reason to know that any of the information or certifications
associated with this documentation is incorrect.
For purposes of this discussion, a "U.S. Controlled Person" means (i) a U.S. person (as defined in the Code), (ii) a
controlled foreign corporation for U.S. federal income tax purposes, (iii) a foreign person 50% or more of whose gross
income was effectively connected with the conduct of a United States trade or business for a specified three-year period,
or (iv) a foreign partnership, if at any time during its tax year, one or more of its partners are U.S. persons who, in the
aggregate, hold more than 50% of the partnership's income or capital interest or if, at any time during its tax year, it is
engaged in the conduct of a trade or business in the United States.
Any amounts withheld under the backup withholding rules may be allowed as a credit against the holder's U.S. federal
income tax liability, and may entitle the holder to a refund, provided that the required information is furnished to the
IRS.
Holders should consult their tax advisers regarding the application of information reporting and backup withholding to
their particular situations, the availability of an exemption therefrom, and the procedure for obtaining an exemption, if
available.
A holder of a Note with a maturity at issue of 183 days or less and a principal amount of at least $500,000 (or its foreign
currency equivalent based on the spot rate on the date of issue), by accepting the Note, will be deemed to represent and
warrant that it is not a United States person (other than an exempt recipient described in section 6049(b)(4) of the Code
and the regulations thereunder), and is not acting for or on behalf of any such person.
IRISH TAXATION
The Issuer is not resident or incorporated in Ireland, nor does it operate through a branch or agency in Ireland. No
register in respect of the Notes, nor any of the Notes themselves are to be physically located in Ireland. Neither the
Issuer nor any Dealer intends to offer any Notes in Ireland. The Issuer, and any Irish Paying Agent acting on behalf of
the Issuer, is not obliged, solely by virtue of the listing of the Notes on the regulated market of the Irish Stock Exchange,
to withhold any amount of Irish tax from payments under the Notes.
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