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date), (ii) increased by the amount of OID previously accrued on the Foreign Currency ContingentNote (disregarding any positive or negative adjustments and translated into U.S. dollars using theexchange rate applicable to such OID) and (iii) decreased by the projected amount of all priorpayments in respect of the Foreign Currency Contingent Note. The U.S. dollar amount of theprojected payments described in clause (iii) of the preceding sentence is determined by (x) firstallocating the payments to the most recently accrued OID to which prior amounts have not alreadybeen allocated and translating those amounts into U.S. dollars at the rate at which the OID wasaccrued and (y) then allocating any remaining amount to principal and translating such amount intoU.S. dollars at the spot rate on the date the Foreign Currency Contingent Note was acquired by theU.S. Holder. For this purpose, any accrued OID reduced by a negative adjustment carry forward willbe treated as principal.The amount realized by a U.S. Holder upon the sale, exchange or retirement of a Foreign CurrencyContingent Note will equal the amount of cash and the fair market value (determined in foreigncurrency) of any property received. If a U.S. Holder holds a Foreign Currency Contingent Note untilits scheduled maturity, the U.S. dollar equivalent of the amount realized will be determined byseparating such amount realized into principal and one or more OID components, based on theprincipal and OID composing the U.S. Holder’s basis, with the amount realized allocated first to OID(and allocated to the most recently accrued amounts first) and any remaining amounts allocated toprincipal. The U.S. dollar equivalent of the amount realized upon a sale, exchange or unscheduledretirement of a Foreign Currency Contingent Note will be determined in a similar manner, but willfirst be allocated to principal and then any accrued OID (and will be allocated to the earliest accruedamounts first). Each component of the amount realized will be translated into U.S. dollars using theexchange rate used with respect to the corresponding principal or accrued OID. The amount of anygain realized upon a sale, exchange or unscheduled retirement of a Foreign Currency Contingent Notewill be equal to the excess of the amount realized over the holder’s tax basis, both expressed inforeign currency, and will be translated into U.S. dollars using the spot rate on the payment date. Gainfrom the sale or retirement of a Foreign Currency Contingent Note will generally be treated as interestincome taxable at ordinary income (rather than capital gains) rates. Any loss will be ordinary loss tothe extent that the U.S. Holder’s total OID inclusions to the date of sale or retirement exceed the totalnet negative adjustments that the U.S. Holder took into account as ordinary loss, and any further losswill be capital loss. Gain or loss realized by a U.S. Holder on the sale or retirement of a ForeignCurrency Contingent Note will generally be foreign source. Prospective purchasers should consulttheir tax advisers as to the foreign tax credit implications of the sale or retirement of Foreign CurrencyContingent Notes.A U.S. Holder will also recognize U.S. source exchange rate gain or loss (taxable as ordinary incomeor loss) on the receipt of foreign currency in respect of a Foreign Currency Contingent Note if theexchange rate in effect on the date the payment is received differs from the rate applicable to theprincipal or accrued OID to which such payment relates.Disposition of Foreign CurrencyForeign currency received as interest on a Note or on the sale or retirement of a Note will have a taxbasis equal to its U.S. dollar value at the time the foreign currency is received. Foreign currency that ispurchased will generally have a tax basis equal to the U.S. dollar value of the foreign currency on thedate of purchase. Any gain or loss recognised on a sale or other disposition of a foreign currency(including its use to purchase Notes or upon exchange for U.S. dollars) will be U.S. source ordinaryincome or loss.332