EFTA Document EFTA01378985

United States Federal Tax Considerations This discussion supplements and, to the extent inconsistent therewith, supersedes the discussion in the accompanying product supplement under 'Material United States Federal Income Tax Considerations." Due to the lack of any controlling legal authority, there is substantial uncertainty regarding the U.S. federal tax consequences of an investment in the securities. In the opinion of our counsel, Davis Polk & Wardwell LLP, it is reasonable under current