EFTA Document EFTA01376291

outstanding prior to March 19, 2012 (as discussed in more detail below, and such withholding or gross income taxes may not be grossed up). In addition, there can be no assurance that income derived by the Issuer will not become subject to withholding or gross income taxes as a result of changes in law, contrary conclusions by the IRS. or other causes. In that event. such withholding or gross income taxes could be applied retroactively to foes or other income previously received by the Issuer