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This excerpt taken from the PBR 20-F filed May 22, 2009. U.S. Federal Income Tax
Considerations
This summary describes the principal tax consequences of the
ownership and disposition of common or preferred shares or ADSs,
based upon the U.S. Internal Revenue Code of 1986, as
amended (the “Code”), its legislative history,
existing and proposed U.S. Treasury regulations promulgated
thereunder, published rulings by the U.S. Internal Revenue
Service (the “IRS), and court decisions, all in effect as
of the date hereof, all of which authorities are subject to
change or differing
interpretations, which changes or differing interpretations
could apply retroactively. This summary does not purport to be a
comprehensive description of all of the tax consequences that
may be relevant to a decision to hold or dispose of common or
preferred shares or ADSs. This summary applies only to
purchasers of common or preferred shares or ADSs who hold the
common or preferred shares or ADSs as “capital assets”
(generally, property for investment), and does not apply to
special classes of holders such as dealers in securities or
currencies, holders whose functional currency is not the
U.S. dollar, holders of 10% or more of our shares (taking
into account shares held directly or through depositary
arrangements), tax-exempt organizations, financial institutions,
holders liable for the alternative minimum tax, securities
traders who elect to account for their investment in common or
preferred shares or ADSs on a mark-to-market basis, and persons
holding common or preferred shares or ADSs in a hedging
transaction or as part of a straddle or conversion transaction.
EACH HOLDER SHOULD CONSULT SUCH HOLDER’S OWN TAX ADVISOR
CONCERNING THE OVERALL TAX CONSEQUENCES TO IT, INCLUDING THE
CONSEQUENCES UNDER LAWS OTHER THAN U.S. FEDERAL INCOME TAX
LAWS, OF AN INVESTMENT IN COMMON OR PREFERRED SHARES OR ADSs.
Shares of our preferred stock will be treated as equity for
U.S. federal income tax purposes. In general, a holder of
an ADS will be treated as the holder of the shares of common or
preferred stock represented by those ADSs for U.S. federal
income tax purposes, and no gain or loss will be recognized if
you exchange an ADS for the shares of common or preferred stock
represented by that ADS.
In this discussion, references to ADSs refer to ADSs with
respect to both common and preferred shares, and references to a
“U.S. holder” are to a holder of an ADS that is:
Table of Contents
This excerpt taken from the PBR 20-F filed Jun 30, 2005. U.S. Federal Income Tax Considerations
The statements regarding U.S. tax law set forth below are based on U.S. law as in force on the date of this annual report, and changes to such law subsequent to the date of this annual report may affect the tax consequences described herein. This summary describes the principal tax consequences of the ownership and disposition of common or preferred shares or ADSs, but it does not purport to be a comprehensive description of all of the tax consequences that may be relevant to a decision to hold or dispose of common or preferred shares or ADSs. This summary applies only to purchasers of common or preferred shares or ADSs who will hold the common or preferred shares or ADSs as capital assets and does not apply to special classes of holders such as dealers in securities or currencies, holders whose functional currency is not the U.S. dollar, holders of 10% or more of our shares (taking into account shares held directly or through depositary arrangements), tax-exempt organizations, financial institutions, holders liable for the alternative minimum tax, securities traders who elect to account for their investment in common or preferred shares or ADSs on a mark-to-market basis, and persons holding common or preferred shares or ADSs in a hedging transaction or as part of a straddle or conversion transaction.
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