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This excerpt taken from the PBR 20-F filed May 22, 2009. Non-U.S.
Holder
A holder or beneficial owner of a note that is not a
U.S. holder (a
non-U.S. holder)
generally will not be subject to U.S. federal income or
withholding tax on interest received on the notes. In addition,
a
non-U.S. holder
will not be subject to U.S. federal income or withholding
tax on gain realized on the sale of notes unless, in the case of
gain realized by an individual
non-U.S. holder,
the
non-U.S. holder
is present in the United States for 183 days or more in the
taxable year of the sale and certain other conditions are met.
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