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issue price of a Foreign Currency Contingent Note will generally be determined under the rulesdescribed above, and will be denominated in the foreign currency of the Foreign Currency ContingentNote.OID on a Foreign Currency Contingent Note will be translated into U.S. dollars under translation rulessimilar to those described above under “— Interest”. Any positive adjustment (i.e. the excess of actualpayments over projected payments) in respect of a Foreign Currency Contingent Note for a taxableyear will be translated into U.S. dollars at the spot rate on the last day of the taxable year in which theadjustment is taken into account, or, if earlier, the date on which the Foreign Currency ContingentNote is disposed of. The amount of any negative adjustment on a Foreign Currency Contingent Note(i.e. the excess of projected payments over actual payments) that is offset against accrued but unpaidOID will be translated into U.S. dollars at the same rate at which the OID was accrued. To the extent anet negative adjustment exceeds the amount of accrued but unpaid OID, the negative adjustment willbe treated as offsetting OID that has accrued and been paid on the Foreign Currency Contingent Note,and will be translated into U.S. dollars at the spot rate on the date the Foreign Currency ContingentNote was issued. Any net negative adjustment carry forward will be carried forward in the relevantforeign currency.Sale or RetirementNotes other than Foreign Currency Contingent NotesAs discussed above under “— Purchase, Sale and Retirement of Notes”, a U.S. Holder will generallyrecognise gain or loss on the sale or retirement of a Note equal to the difference between the amountrealised on the sale or retirement and its tax basis in the Note. A U.S. Holder’s tax basis in a Note thatis denominated in a foreign currency will be determined by reference to the U.S. dollar cost of theNote. The U.S. dollar cost of a Note purchased with foreign currency will generally be the U.S. dollarvalue of the purchase price on the date of purchase, or the settlement date for the purchase, in the caseof Notes traded on an established securities market, as defined in the applicable Treasury Regulations,that are purchased by a cash basis U.S. Holder (or an accrual basis U.S. Holder that so elects).The amount realised on a sale or retirement for an amount in foreign currency will be the U.S. dollarvalue of this amount on the date of sale or retirement, or the settlement date for the sale, in the case ofNotes traded on an established securities market, as defined in the applicable Treasury Regulations,sold by a cash basis U.S. Holder (or an accrual basis U.S. Holder that so elects). Such an election byan accrual basis U.S. Holder must be applied consistently from year to year and cannot be revokedwithout the consent of the IRS.A U.S. Holder will recognise U.S. source exchange rate gain or loss (taxable as ordinary income orloss) on the sale or retirement of a Note equal to the difference, if any, between the U.S. dollar valuesof the U.S. Holder’s purchase price for the Note (or, if less, the principal amount of the Note) (i) onthe date of sale or retirement and (ii) the date on which the U.S. Holder acquired the Note. Any suchexchange rate gain or loss will be realised only to the extent of total gain or loss realised on the sale orretirement (including any exchange gain or loss with respect to the receipt of accrued but unpaidinterest).Foreign Currency Contingent NotesUpon a sale, exchange or retirement of a Foreign Currency Contingent Note, a U.S. Holder willgenerally recognize taxable gain or loss equal to the difference between the amount realized on thesale, exchange or retirement and the U.S. Holder’s tax basis in the Foreign Currency Contingent Note,both translated into U.S. dollars as described below. A U.S. Holder’s tax basis in a Foreign CurrencyContingent Note will equal (i) the cost thereof (translated into U.S. dollars at the spot rate on the issue331