Dit prospectus is gemaakt voor de uitgifte van dit product en ... - Iex

the reduced rate described above under “— Distributions on Equity Notes — General”, and exceeds10 per cent. of the U.S. Holder’s basis in its Equity Notes. Any gain or loss will generally be U.S.source.A U.S. Holder’s tax basis in an Equity Note will generally be its U.S. dollar cost. The U.S. dollar costof a Share purchased with foreign currency will generally be the U.S. dollar value of the purchaseprice on the date of purchase, or the settlement date for the purchase, in the case of Equity Notestraded on an established securities market, as defined in the applicable Treasury Regulations, that arepurchased by a cash basis U.S. Holder (or an accrual basis U.S. Holder that so elects). Such anelection by an accrual basis U.S. Holder must be applied consistently from year to year and cannot berevoked without the consent of the IRS.The amount realised on a sale or other disposition of Equity Notes for an amount in foreign currencywill be the U.S. dollar value of this amount on the date of sale or disposition. On the settlement date,the U.S. Holder will recognise U.S. source foreign currency gain or loss (taxable as ordinary incomeor loss) equal to the difference (if any) between the U.S. dollar value of the amount received based onthe exchange rates in effect on the date of sale or other disposition and the settlement date. However,in the case of Equity Notes traded on an established securities market that are sold by a cash basisU.S. Holder (or an accrual basis U.S. Holder that so elects), the amount realised will be based on theexchange rate in effect on the settlement date for the sale, and no exchange gain or loss will berecognised at that time.Disposition of Foreign CurrencyForeign currency received on the sale or other disposition of an Equity Note will have a tax basisequal to its U.S. dollar value on the settlement date. Foreign currency that is purchased will generallyhave a tax basis equal to the U.S. dollar value of the foreign currency on the date of purchase. Anygain or loss recognised on a sale or other disposition of a foreign currency (including its use topurchase Equity Notes or upon exchange for U.S. dollars) will be U.S. source ordinary income or loss.Forward NotesGeneralA Note that provides for a payment in redemption at maturity that is based on the value of one ormore Reference Items (whether physically settled by delivery of those Reference Items or settled incash) and does not provide for a current coupon, may be identified as a “Forward Note” by the Issuerin the relevant Final Terms or any prospectus or series prospectus. A U.S. Holder of a Forward Notewould generally be subject to the U.S. federal income tax consequences discussed below.Legislation was recently proposed in the U.S. House of Representatives that would require a holder ofan instrument such as a Forward Note to accrue interest income on a current basis in certaincircumstances. In addition, the IRS and the U.S. Department of Treasury have recently announced thatthey are considering whether the holder of an instrument such as a Forward Note should be required toaccrue ordinary income on a current basis. It is not possible to predict the final form of any legislativeor regulatory changes that might affect holders of instruments such as the Forward Notes, but it ispossible that any such changes could be applied retroactively. The IRS and U.S. Department ofTreasury are also considering other relevant issues, including whether gain or loss from theseinstruments should be treated as ordinary or capital, whether foreign holders of these instrumentsshould be subject to withholding tax on any deemed income accruals, and whether the specialconstructive ownership rules of Section 1260 of the Code might be applied to these instruments.Holders are urged to consult their tax advisers concerning the potential impact of these proposals. The334