| DIVIDENDS AND DISTRIBUTIONS INFORMATION |
| TAX MATTERS |
The following discussion of federal income tax matters is based on the advice of our counsel, Paul,
Hastings, Janofsky & Walker LLP.
This section and the discussion in our statement of additional information summarize the material consequences to U.S. taxpayers of owning our common stock. Tax laws and interpretations change frequently, and this summary does not describe all of the tax consequences to all taxpayers. For example, this summary generally does not describe your situation if you are a non-U.S. person, a broker-dealer, or other investor with special circumstances. In addition, this section generally does not describe your state, local or foreign tax consequences. As with any investment, you should consult your own professional tax advisor regarding the tax consequences of investing in our common stock.
Use of Tax Matters Section As required by U.S. Treasury Regulations governing tax practice, you are hereby advised that any written tax advice contained herein was not written or intended to be used (and cannot be used) by any taxpayer for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code. The advice was prepared to support the promotion or marketing of the transactions or matters addressed by the written advice. Any person reviewing this discussion should seek advice based on such person’s particular circumstances from an independent professional tax advisor. Any person reviewing this discussion should seek advice based on such person’s particular circumstances from an independent tax advisor. |
