INDEX OF DEFINED TERMS - Banca di Legnano

Level: 2 – From: 2 – Wednesday, July 21, 2010 – 13:20 – eprint6 – 4247 Section 10
United States Taxation
UNITED STATES TAXATION
TO ENSURE COMPLIANCE WITH U.S. TREASURY DEPARTMENT CIRCULAR 230,
NOTEHOLDERS ARE HEREBY NOTIFIED THAT: (A) ANY DISCUSSION OF UNITED STATES
FEDERAL TAX ISSUES IN THIS OFFERING CIRCULAR IS NOT INTENDED OR WRITTEN TO BE
RELIED UPON, AND CANNOT BE RELIED UPON BY NOTEHOLDERS FOR THE PURPOSE OF
AVOIDING PENALTIES THAT MAY BE IMPOSED ON NOTEHOLDERS UNDER THE INTERNAL
REVENUE CODE; (B) SUCH DISCUSSION IS INCLUDED HEREIN BY THE ISSUER IN
CONNECTION WITH THE PROMOTION OR MARKETING (WITHIN THE MEANING OF
CIRCULAR 230) BY THE ISSUER AND ANY DEALER OF THE TRANSACTIONS OR MATTERS
ADDRESSED HEREIN; AND (C) NOTEHOLDERS SHOULD SEEK ADVICE BASED ON THEIR
PARTICULAR CIRCUMSTANCES FROM AN INDEPENDENT TAX ADVISOR.
Except as otherwise provided in the applicable Final Terms, the following is a summary of certain
United States federal income tax considerations applicable to an investment in the Notes by United States
Alien holders who are the original purchasers of the Notes and who, except to the extent specifically
provided, have not purchased, and do not hold, the Notes in connection with a United States trade or
business. For purposes of the following discussion it is assumed that Bearer Notes will be in bearer form,
the Principal Agent will deliver the Bearer Notes to the holders or their agents outside the United States
and its possessions and that none of Euroclear or Clearstream, Luxembourg (or the participants of either),
the Common Depositary, or the Common Safekeeper, as the case may be, is or will act as the Issuer’s
agent with respect to any matter relating to the Bearer Notes, including ownership thereof or any payments
with respect thereto.
This summary is for general information only, and does not purport to discuss all aspects of United
States federal income taxation that may be important to a particular holder in light of its circumstances or
to holders subject to special tax rules, such as trusts, estates and controlled foreign corporations, or the
beneficiaries or stockholders of such entities.
If an entity or arrangement treated as a partnership for U.S. federal income tax purposes holds the
Notes, the U.S. federal income tax treatment of a partner generally will depend upon the status of the
partner and the activities of the partnership. A partner of a partnership holding the Notes should consult its
own tax advisor regarding the U.S. federal income tax consequences to the partner of the acquisition,
ownership, and disposition by the partnership of the Notes.
Bearer Notes Other than Structured Notes
In respect of Bearer Notes other than Bearer Notes that are specified as “Structured Notes” in the
applicable Final Terms, under the United States federal income tax laws as in effect on the date of this
Offering Circular and subject to the discussion below, payments of principal and interest (including
original issue discount), if any, by the Issuer or any Paying Agent (acting in its capacity as such) outside
the United States and its possessions to any holder of a Bearer Note (other than Dual Currency Notes) who
is a United States Alien generally will not be subject to United States federal income or withholding tax, in
the case of interest (including original issue discount) provided that:
(a)
(b)
such holder does not actually or constructively own 10.00 per cent. or more of the total
combined voting power of all classes of stock of the Issuer entitled to vote;
such holder is not a controlled foreign corporation for United States federal income tax
purposes that is related to the Issuer (directly or indirectly) through stock ownership;
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