Landeskreditbank Baden-Württemberg - L-Bank
Landeskreditbank Baden-Württemberg - L-Bank
Landeskreditbank Baden-Württemberg - L-Bank
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will equal such U.S. Holder’s initial investment in the Debt Security increased by any original issue discount<br />
included in income and decreased by any payment on the Debt Security other than a payment of qualified stated<br />
interest. Any gain or loss recognized on a sale, retirement or other disposition of a Debt Security, other than<br />
amounts attributable to interest, generally will be treated as U.S. source gain or loss and generally will be longterm<br />
capital gain or loss if the Debt Security was held for more than one year. In the case of a U.S. Holder who is<br />
an individual, capital gains, if any, generally will be subject to U.S. federal income taxation at preferential rates if<br />
specified minimum holding periods are met. The deductibility of capital losses is subject to limitations.<br />
Optional Redemption<br />
Certain of the Debt Securities may be redeemable at our option prior to their stated maturity and/or may be<br />
repayable at the option of the holder prior to their stated maturity. Debt Securities containing such features may<br />
be subject to rules that differ from the general rules discussed above. Investors intending to purchase Debt<br />
Securities with such features should carefully examine the applicable prospectus supplement and should consult<br />
their own tax advisors, since the tax consequences with respect to original issue discount will depend, in part, on<br />
the particular terms and features of the purchased Debt Securities.<br />
Election to Treat All Interest as Original Issue Discount<br />
A U.S. Holder generally may elect to include in income all interest (including stated interest, original issue<br />
discount, de minimis original issue discount and unstated interest) that accrues on a Debt Security by using the<br />
constant yield method applicable to original issue discount, subject to certain limitations and exceptions. The<br />
election may not be revoked without the consent of the IRS. U.S. Holders should consult their own tax advisors<br />
regarding the advisability of making this election.<br />
Short-Term Debt Securities<br />
Debt Securities that have a fixed maturity of one year or less (“Short-Term Debt Securities”) generally will<br />
be treated as having been issued with original issue discount in an amount equal to the excess of the sum of the<br />
total principal and the interest payments on the Debt Security over its issue price. Except as noted below, an<br />
individual and certain other cash method U.S. Holders generally are not required to include accrued original issue<br />
discount on Short-Term Debt Securities in their income currently. However, such Holders may be required to<br />
include any stated interest in income when the interest is received if such receipt occurs prior to maturity. Any<br />
gain realized by such U.S. Holders on the sale, exchange or maturity of Short-Term Debt Securities generally<br />
will be ordinary income to the extent of the original issue discount accrued through the date of the sale,<br />
retirement or other disposition. In addition, a portion of the deductions otherwise allowable to the U.S. Holder for<br />
interest on borrowings allocable to the Short-Term Debt Security may be required to be deferred until the Debt<br />
Security matures. Notwithstanding the foregoing, a cash method U.S. Holder of a Short-Term Debt Security may<br />
elect to accrue original issue discount on a current basis (in which case the limitation on the deductibility of<br />
interest described above will not apply). U.S. Holders who report income for United States federal income tax<br />
purposes under the accrual method, and certain other holders (including banks and dealers in securities), are<br />
required to accrue original issue discount on a Short-Term Debt Security on a straight-line basis unless an<br />
election is made to accrue the original issue discount under a constant yield method (based on daily<br />
compounding).<br />
In the case of a Short-Term Debt Security that is also a single Foreign Currency Debt Security, the amount<br />
of original issue discount subject to current accrual and the amount of any exchange gain or loss on a sale,<br />
retirement or other disposition generally are determined under the same rules that apply to accrued interest on a<br />
single Foreign Currency Debt Security held by a holder using the accrual method of accounting.<br />
Investors considering the purchase of Short-Term Debt Securities should carefully examine the applicable<br />
prospectus supplement and should consult their tax advisors regarding the U.S. federal income tax consequences<br />
of holding and disposing of such Debt Securities.<br />
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