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

“Option Note” by the Issuer. The discussion below describes the U.S. federal income taxconsequences to a U.S. Holder of holding Option Notes.The treatment of Option Notes for U.S. federal income tax purposes is highly uncertain. It would bereasonable to treat the purchase of an Option Note by a U.S. Holder as a grant by the U.S. Holder tothe Issuer of an option contract (the “Put Option”), pursuant to which the U.S. Holder may berequired to purchase from the Issuer one or more of the Reference Items (or an amount equal to thevalue of the Reference Items in the case of a cash settled Option Note), and under which option (a) atthe time of the issuance of the Option Note the U.S. Holder deposits irrevocably with the Issuer afixed amount of cash to assure the fulfilment of the holder’s purchase obligation described below (the“Deposit”), (b) until maturity the Issuer will be obligated to pay interest to the U.S. Holder, ascompensation for the use of the cash Deposit during the term of the Option Note, (c) the Issuer will beobligated to pay an option premium to the holder in consideration for granting the option (the “PutPremium”), which premium will be payable as part of the coupon payments, (d) if pursuant to theterms of the Option Notes at maturity the holder is obligated to purchase the Reference Item(s), thenthe Deposit will be applied by the Issuer in full satisfaction of the holder’s purchase obligation underthe Put Option, and the Issuer will deliver to the holder the number of Reference Items that the holderis entitled to receive at that time pursuant to the terms of the Notes (or, if the Option Notes are cashsettled, a cash amount equal to the value of the Reference items), and (e) if pursuant to the terms ofthe Option Notes the holder is not obligated to purchase the Reference Items at maturity, the Issuerwill return the cash Deposit to the U.S. Holder at maturity. The discussion below assumes that anOption Note is so treated, except as explicitly provided.Amounts paid to the Issuer in respect of the original issue of the Option Notes will be treated asallocable in their entirety to the amount of the cash Deposit attributable to such Notes. A portion ofthe coupon on the Notes (which coupon may be denominated entirely as stated interest) will becharacterised as interest payable on the amount of such Deposit, includible in the income of a U.S.Holder as interest in the manner described below. A portion of the coupon will be characterised as PutPremium, includible in the income of a U.S. Holder in the manner described below. There is noassurance that the IRS will agree with this treatment, and alternative treatments of the Option Notescould result in less favourable U.S. federal income tax consequences to a holder, including arequirement to accrue income with respect to the Put Option on a current basis.Interest PaymentsInterest payments on the Deposit will generally be included in the income of a U.S. Holder as interestat the time that such interest is accrued or received in accordance with such U.S. Holder’s method ofaccounting. If the Option Notes are issued at a discount or have a term of one year or less, U.S.Holders will be subject to the rules discussed above under “— U.S. Federal Income Tax Treatment ofNotes Treated as Debt — Original Issue Discount” with respect to interest or OID payable on theDeposit. Interest paid by the Issuer and OID, if any, accrued with respect to the Option Notes,generally constitute income from sources outside the United States.Payments of Put PremiumPayments of the Put Premium will not be included in the income of a U.S. Holder until sale or othertaxable disposition of Option Notes or retirement of Option Notes for cash; if the Option Note issettled by delivery of Reference Items, the payments of Put Premium will instead be incorporated intothe U.S. Holder’s basis in such Reference Items. Upon the sale or other taxable disposition of OptionNotes or at maturity, as the case may be, the Put Premium payment will be treated in the mannerdescribed below.336