EFTA Document EFTA01381326

Form S-I Table of Contrail will constitute a return of capital and first be applied against and reduce a non-U.S. Holder's adjusted tax basis in its common stock. but not below zero. Any excess will be treated as capital gain and will be treated as described below under "Gain on Disposition of Common Stock." Dividends paid to a non-U.S. Holder of our common stock generally will be subject to withholding of United States federal income tax at a 30% rate or such lower rate as may be specified