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Contingent NotesGain from the sale or retirement of a Contingent Note will be treated as interest income taxable atordinary income (rather than capital gains) rates. Any loss will be ordinary loss to the extent that theU.S. Holder’s total interest inclusions to the date of sale or retirement exceed the total net negativeadjustments that the U.S. Holder took into account as ordinary loss, and any further loss will becapital loss. Gain or loss realised by a U.S. Holder on the sale or retirement of a Contingent Note willgenerally be foreign source.A U.S. Holder’s tax basis in a Contingent Note will generally be equal to its cost, increased by theamount of interest previously accrued with respect to the Note (determined without regard to anypositive or negative adjustments reflecting the difference between actual payments and projectedpayments), increased or decreased by the amount of any positive or negative adjustment that theHolder is required to make to account for the difference between the Holder’s purchase price for theNote and the adjusted issue price of the Note at the time of the purchase, and decreased by the amountof any projected payments scheduled to be made on the Note to the U.S. Holder through such date(without regard to the actual amount paid).Foreign Currency NotesInterestIf an interest payment is denominated in, or determined by reference to, a foreign currency, theamount of income recognised by a cash basis U.S. Holder will be the U.S. dollar value of the interestpayment, based on the exchange rate in effect on the date of receipt, regardless of whether thepayment is in fact converted into U.S. dollars.An accrual basis U.S. Holder may determine the amount of income recognised with respect to aninterest payment denominated in, or determined by reference to, a foreign currency in accordance witheither of two methods. Under the first method, the amount of income accrued will be based on theaverage exchange rate in effect during the interest accrual period (or, in the case of an accrual periodthat spans two taxable years of a U.S. Holder, the part of the period within the taxable year).Under the second method, the U.S. Holder may elect to determine the amount of income accrued onthe basis of the exchange rate in effect on the last day of the accrual period (or, in the case of anaccrual period that spans two taxable years, the exchange rate in effect on the last day of the part ofthe period within the taxable year). Additionally, if a payment of interest is actually received withinfive business days of the last day of the accrual period, an electing accrual basis U.S. Holder mayinstead translate the accrued interest into U.S. dollars at the exchange rate in effect on the day ofactual receipt. Any such election will apply to all debt instruments held by the U.S. Holder at thebeginning of the first taxable year to which the election applies or thereafter acquired by the U.S.Holder, and will be irrevocable without the consent of the IRS.Upon receipt of an interest payment (including a payment attributable to accrued but unpaid interestupon the sale or retirement of a Note) denominated in, or determined by reference to, a foreigncurrency, the U.S. Holder may recognise U.S. source exchange gain or loss (taxable as ordinaryincome or loss) equal to the difference between the amount received (translated into U.S. dollars at thespot rate on the date of receipt) and the amount previously accrued, regardless of whether the paymentis in fact converted into U.S. dollars.329