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What are the tax implications?

  • All prospective purchasers of the Notes are advised to consult their own tax advisors regarding the U.S. federal, state, local and non-U.S. tax consequences of the purchase and ownership of the Notes (including any possible differing treatments of the Notes). 
  • A holder of a Note will be required to include the OID1 in income as ordinary interest income for U.S. federal income tax purposes as it accrues (which may be in advance of interest being paid on the Note), regardless of such holder’s regular method of accounting.

1 Original issue discount (OID) is a form of interest. It's taxable as it accrues over the term of the bond/note.

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