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sd-10-EFTA01459327Dept. of Justice

EFTA Document EFTA01459327

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Tax Treatment You should review carefully the section entitled 'Material U.S. Federal Income Tax Consequences" in the accompanying product supplement no. 4a-l. The following discussion, when read in combination with that section, constitutes the full opinion of our special tax counsel, Davis Polk & Wardwell LLP, regarding the material U.S. federal income tax consequences of owning and disposing of notes. Based on current market conditions, in the opinion of our special tax counsel it is reas

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Dept. of Justice
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sd-10-EFTA01459327
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