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

Issuers intend to treat the Forward Notes as described below, unless and until the Issuers determine,based on future developments, that a different treatment is appropriate.CharacterisationA Forward Note should constitute a prepaid forward contract for U.S. federal income tax purposes.Under current law, U.S. Holders should not be required to recognise income or loss upon theacquisition of a Note, and U.S. Holders should not be required to accrue income with respect to a Noteover the life of the Note.Purchase, Sale and RetirementA U.S. Holder will recognise gain or loss on the sale or retirement for cash of a Forward Note equal tothe difference between the amount of cash received upon sale or retirement and the U.S. Holder’s taxbasis in the Note. A U.S. Holder’s tax basis in a Forward Note will generally be the Note’s U.S. dollarcost. The U.S. dollar cost of a Forward Note purchased with a foreign currency will generally be theU.S. dollar value of the purchase price on the date of purchase increased by the nominal exerciseprice, if any, paid by the U.S. Holder. Except as provided under “— Constructive OwnershipTransactions” below, any gain or loss recognised on the sale or retirement of a Forward Note will becapital gain or loss and will be long-term capital gain or loss if the U.S. Holder’s holding period in theNote exceeds one year.Upon a retirement of a Forward Note by physical delivery of the Reference Items, a U.S. Holder willnot be required to recognise gain or loss at that time. A U.S. Holder will have a basis in the ReferenceItems equal to the U.S. Holder’s basis in the Forward Note. A U.S. Holder’s holding period in theReference Items will not include the U.S. Holder’s holding period in the Forward Notes.Constructive Ownership TransactionsTo the extent that a Forward Note is treated as a “constructive ownership transaction,” any gain ondisposition may be treated as ordinary income and an interest charge may be imposed on a deemedunderpayment of tax for each taxable year during which the Note was held. For purposes ofdetermining the interest charge, gain treated as ordinary income is allocated to each such taxable yearduring which the Forward Note was held so that the amount of gain accrued from each year to thenext increases at a constant rate equal to the “applicable federal rate” (a rate published monthly by theIRS based on prevailing Treasury yields) in effect at the time the Note is sold or redeemed.A Note could be treated in whole or in part as a constructive ownership transaction if the issuer of aReference Item and, if the Reference Item is an index, possibly the issuer of any security included inthat index is treated for U.S. federal income tax purposes as, among others, a PFIC, a partnership, atrust, or a common trust fund.The Issuer does not intend to determine whether the issuers of any Reference Item in fact fall in any ofthese categories. Prospective purchasers should consult their tax advisers regarding the status of theReference Items and the application of the constructive ownership transaction rules to ownership ofthe Note.Option NotesA Note that provides for a payment in redemption at maturity that may under certain circumstances bebased on the value of one or more Reference Items (whether physically settled by delivery of thoseReference Items or settled in cash) and also provides for a current coupon, may be identified as an335