|
|
 | | | |
- close
- close
- close
- close
This excerpt taken from the PBR 20-F filed May 22, 2009. U.S.
Federal Income Taxation
The following summary sets forth certain United States federal
income tax considerations that may be relevant to a holder of a
note that is, for U.S. federal income purposes, a citizen
or resident of the United States or a domestic corporation or
that otherwise is subject to U.S. federal income taxation
on a net income basis in respect of the notes (a
“U.S. holder”). This summary is based upon the
Code, its legislative history, existing and proposed
U.S. Treasury regulations promulgated thereunder, published
rulings by the U.S. Internal Revenue Service, or 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
discuss all aspects of the United States federal income taxation
which may be relevant to special classes of investors, such as
financial institutions, insurance companies, dealers or traders
in securities or currencies, regulated investment companies,
tax-exempt organizations, certain short-term holders of notes,
persons that hedge their exposure in the notes or hold notes as
part of a position in a “straddle” or as part of a
hedging transaction or “conversion transaction” for
U.S. federal tax purposes, persons that enter into a
“constructive sale” transaction with respect to the
notes or U.S. holder whose functional currency is not the
U.S. dollar. U.S. holders should be aware that the
U.S. federal income tax consequences of holding the notes
may be materially different for investors described in the prior
sentence.
In addition, this summary does not discuss any foreign, state or
local tax considerations. This summary only applies to original
purchasers of notes who purchase notes at the original issue
price and hold the notes as “capital assets”
(generally, property held for investment) within the meaning of
Section 1221 of the Code.
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 THE NOTES.
This excerpt taken from the PBR 20-F filed Jun 30, 2005. U.S. Federal Income Taxation
The following summary sets forth certain United States federal income tax considerations that may be relevant to a holder of a note that is, for U.S. federal income purposes, a citizen or resident of the United States or a domestic corporation or that otherwise is subject to Untied States federal income tax on a net income basis in respect of the notes (a “U.S. holder”). This summary is based upon the Code, its legislative history, existing and proposed U.S. Treasury regulations promulgated thereunder, published rulings by the U.S. Internal Revenue Service, or 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 discuss all aspects of United States federal income taxation which may be relevant to particular investors, such as financial institutions, insurance companies, dealers or traders in securities or currencies, regulated investment companies, tax-exempt organizations, certain short-term holders of notes, persons that hedge their exposure in the notes or hold notes as part of a position in a “straddle” or as part of a hedging transaction or “conversion transaction” for U.S. federal tax purposes, persons that enter into a “constructive sale” transaction with respect to the notes or U.S. Holder whose functional currency as defined in Section 985 of the code is not the U.S. dollar. U.S. holders should be aware that the U.S. federal income tax consequences of holding the notes may be materially different for investors described in the prior sentence.
164
Table of ContentsIn addition, this summary does not discuss any foreign, state or local tax considerations. This summary only applies to original purchasers of notes who purchase notes at the original issue price and hold the notes as “capital assets” (generally, property held for investment) within the meaning of Section 1221 of the Code.
| EXCERPTS ON THIS PAGE:
|
| |||||||
