Table of Contents
MATERIAL UNITED STATES FEDERAL INCOME TAX CONSIDERATIONS OF THE EXCHANGE OFFER
The exchange of the Old Notes for New Notes pursuant to the Exchange Offer should not be a taxable event for United States federal income tax
purposes. Accordingly, you should not recognize gain or loss upon the exchange of the Old Notes for the New Notes, and your basis and holding period in the New Notes should equal your basis and
holding period in the Old Notes exchanged for them. In addition, you should be subject to U.S. federal income tax in respect of the New Notes in the same manner as with respect to the Old Notes.