F O R E I G N A C C O U N T T A X C O M P L I A N C E A C T : C U R R E N T D E V E L O P M E N T S

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1 S T R I C T L Y P R I V A T E A N D C O N F I D E N T I A L F O R E I G N A C C O U N T T A X C O M P L I A N C E A C T : C U R R E N T D E V E L O P M E N T S J.P. Morgan Corporate & Investment Bank Presented by Client Tax Services As of June 10, 2014

2 Agenda Page Agenda 1 Overview of FATCA, FATCA Registration and Recent Developments 2 Timeline 6 New and Preexisting Account Due Diligence Requirements 8 Withholding Requirements 11 Reporting Requirements 14 Intergovernmental Agreements and OECD CRS 16 Appendix 22 1

3 Agenda Agenda 1 Page Overview of FATCA, FATCA Registration and Recent Developments 2 Timeline 6 New and Preexisting Account Due Diligence Requirements 8 Withholding Requirements 11 Reporting Requirements 14 Intergovernmental Agreements and OECD CRS 16 Appendix 22 2

4 Overview of FATCA Purpose and Scope The Foreign Account Tax Compliance Act (FATCA), introduced as part of the HIRE Act in 2010, is designed to compel foreign financial institutions (FFIs) and non-financial foreign entities (NFFEs) to provide information to the U.S. Internal Revenue Service (IRS) about U.S. persons who hold accounts with or interests in FFIs or NFFEs. FATCA introduces new requirements on both U.S. withholding agents and certain participating FFIs (PFFIs) entering into FATCA agreements with the IRS relating to: Account documentation and due diligence, with emphasis on identifying U.S. owned accounts and U.S. payees 30% FATCA tax on FATCA withholdable payments to foreign entities that do not document a compliant FATCA tax status (includes undocumented accounts) New and expanded tax reporting on Forms 1042, 1042-S and 8966 Key Effective Dates *. The biggest challenge that we currently face is the uncertainty regarding the finalization of local rules in FATCA Intergovernmental Agreement countries and instructions to tax certification and reporting forms. Key Effective Dates * January 1, 2014 First day to submit FFI registration via online Registration System or Form 8957 May 5, 2014 June 2, 2014 June 3, 2014 July 1, 2014 July 1, 2014 July 1, 2014 December 31, 2014 January 1, 2015 March 15 & 31, 2015 June 30, 2016 Last day to complete registration of an FFI to ensure inclusion on first published IRS list of FFIs (unofficial) IRS will publish online the first list of registered FFIs & FATCA GIIN numbers (to be updated monthly) Last day to complete registration of an FFI to ensure inclusion on IRS list of FFIs published July 1, 2014 (unofficial) New account documentation and due diligence begins on new accounts opened by individuals Withholding begins for any entity account documented as a nonparticipating FFI (NPFFI) End of FATCA withholding safe harbor exception for grandfathered obligations Deadline to complete due diligence for Prima Facie FFI accounts Withholding begins on new accounts opened by entities not documented as FATCA compliant FATCA reporting commences with respect to 2014 (limited reporting) Deadline to complete due diligence for all other preexisting accounts (one year earlier for high value accounts of PFFIs) * See detailed timeline later in presentation 3

5 F O R E I G N A C C O U N T T A X C O M P L I A N C E A C T FATCA Registration of Foreign Financial Institutions Online Registration System On August 19, 2013, the IRS opened the online FATCA Registration System, and released Form 8957 to allow paper registration The IRS encourages, but does not require, FATCA registration through the Registration System Effective January 1, 2014, financial institutions were allowed to submit registrations online or using Form 8957 FATCA Global Intermediary Identification Numbers (GIINs) are now being issued GIIN validation user guide (Publication 5124) published on the IRS website and available at this link: Key Registration Resources FATCA Registration and Support Website User Guide: A 122-page instruction guide regarding the online registration process. Overview: A four-page explanation of the FATCA Registration process. Tips for Logging into the FATCA Registration System: A two-page list of Registration tips. Form 8957, Foreign Account Tax Compliance Act (FATCA) Registration GIIN Composition: FATCA-Registration ions/fatca_registration_overview.pdf Tips-for-Logging-into-the-FATCA-Registration- System With instructions: ions/giin_composition.pdf 4

6 F O R E I I G N A C C C C O U N T T A X C O M P L I I A N C C E E A C T : C U R R E N T D E V E L O P M E N T S Recent Developments IRS Regulations revising and further clarifying the final FATCA regulations issued February 20, 2014 On April 2, 2014, the IRS announced (Announcement ) that jurisdictions that have reached agreements in substance with the U.S. on the terms of an IGA will be treated as having an IGA in effect until December 31, 2014, the date by which the IGA must be signed in order for this status to continue without interruption. On May 2, 2014, the IRS announced (Notice ) that calendar years 2014 and 2015 will be regarded as a transition period for purposes of IRS enforcement and administration of FATCA where the impacted entity has made a good faith effort to comply. In Notice , the IRS also announced that accounts opened by entities between July 1 and December 31, 2014 may be treated as preexisting accounts. Revised IRS Forms W-8BEN, W-8ECI, and W-8EXP have been released with instructions. Revised IRS Forms W-8BEN-E and W-8IMY have been released, instructions are still pending. Further to Notice from the IRS, the UK Tax Authorities ( HMRC ) have announced that Ministers had decided not to adopt any extension to the timeline for on-boarding new entity accounts. Accordingly, UK Financial Institutions will be required to obtain self certifications from new customers (both entities and individuals) from July 1, HMRC has also published the UK FATCA Schema on May 5, All Model IGA Agreements were updated on June 6,

7 Agenda Page Agenda 1 Overview of FATCA, FATCA Registration and Recent Developments 2 Timeline 6 New and Preexisting Account Due Diligence Requirements 8 Withholding Requirements 11 Reporting Requirements 14 Intergovernmental Agreements and OECD CRS 16 Appendix 22 6

8 Reporting Withholding New/Preexisting Accounts General Compliance Key Effective Dates for USWAs and PFFIs FATCA Timeline FATCA Compliance Action Items Grandfathered obligations [must be issued by this date] Jun 30 Effective date of FFI Agreement for FFIs registering by May 5, 2014 Transition period for expanded affiliated group rule (requires affiliates to maintain FATCA-compliant tax status) USWA: Begin new account on-boarding under FATCA documentation and due diligence requirements USWA: Complete re-documentation and due diligence of preexisting accounts PFFI: Begin new account on-boarding under FATCA documentation and due diligence requirements Jul 1 Jan 1 Jan 1 (entity accounts) Jul 1 (individual accounts) Dec 31 June 30 - All other accounts Prima Facie FFIs Jan 1 (entity accounts) Jul 1 (individual accounts) PFFI: Complete re-documentation and due diligence of preexisting accounts Jun 30 - High Value Individuals Jun 30 - All other accounts Dec 31 - Prima Facie FFIs Begin income withholding Jul 1 Begin gross proceeds withholding Jan 1 Begin foreign-passthru payments withholding [ no earlier than this date; requires implementing regulations] Jan 1 PFFI: Begin U.S. account information and balance reporting * PFFI: Begin U.S. account income reporting * Mar 31 Mar 31 PFFI: Begin U.S. account gross proceeds reporting * Mar 31 PFFI: Begin reporting on recalcitrant accounts (for 2014) # and account balances* Mar 31 PFFI: Begin aggregate reporting on NPFFI payments (only for 2015 & 2016)*. See U.K. IGA Mar 31 Mar 31 USWA: Begin U.S. owner reporting for passive NFFEs/ODFFIs* (except on U.S. PFFI pools). USWA: Begin reporting on "reportable amounts" i.e., U.S. FDAP **. See U.K. IGA Mar 31 Mar 15 USWA: Begin reporting on gross proceeds ** Mar 15 Final FATCA Regulations * Form 8966 ** Form 1042-S *** Form

9 Agenda Page Agenda 1 Overview of FATCA, FATCA Registration and Recent Developments 2 Timeline 6 New And Preexisting Account Due Diligence Requirements 8 Withholding Requirements 11 Reporting Requirements 14 Intergovernmental Agreements and OECD CRS 16 Appendix 22 8

10 New and Preexisting Account Due Diligence Requirements New Accounts Documentation and Due Diligence Requirements Step 1 Identify Financial Accounts Step 2 Is it a New Account for FATCA purposes? - A `new account opened by the owner of a FATCA Preexisting Account may be treated as a Preexisting Account if certain criteria are satisfied (single account for AML purposes; Due Diligence balance aggregation; form-sharing) Step 3 - Documentation must be collected on which to determine and support FATCA status. U.S. tax documentation (Forms W-9 and W-8) and/or Self-Certification Statements in FATCA Intergovernmental Agreement (IGA) countries. Documentary evidence in lieu of tax forms provides flexibility but introduces subjectivity. Documentation must be sufficient to reliably support FATCA status. Rules and internal policies may differ for onshore versus offshore offices (or IGA vs. non-iga jurisdiction). Step 4 Validate documentation collected, determine if documentation conflicts with other documentation or information (e.g., Anti-Money Laundering documentation), determine if indicia of U.S. status exist. - U.S. Indicia include: U.S mailing address; classification as U.S. in internal files; standing instructions to pay offshore account funds to onshore account; U.S. telephone number; Power of Attorney or signature authority granted to U.S. person; and in care of or hold mail address is the sole address. - Depending on the specific indicia, a documentary cure is required to treat the account as foreign - Validation may include review of AML documents. Step 5 Classify and record FATCA status of new accounts in on-boarding systems. Step 6 Going forward, monitor account for changes in circumstances which may change FATCA status, and satisfy record retention requirements. Presumption rules will be applied for undocumented accounts; generally, individuals will be presumed U.S. and entities will be presumed NPFFIs. 9

11 F O R E I I G N A C C C C O U N T T A X C O M P L I I A N C C E E A C T : C U R R E N T D E V E L O P M E N T S New and Preexisting Account Due Diligence Requirements (cont.) Preexisting Accounts Any account that is not a New Account Documentation and Due Diligence Requirements Step 1 Identify Preexisting Accounts. Step 2 Identify Prima Facie FFI accounts. - For offices within the U.S., identify by list of NAIC and SIC codes, plus intermediaries (qualified or not). - For offices outside the U.S., Prima Facie FFIs include only intermediaries. - Prima Facie FFIs have an accelerated timeline for documenting a compliant FATCA status (by end of 2014). - REMAINING PFFIs must document a FATCA compliant FATCA status by June 30, Step 3 Determine FATCA status. Review existing documentation such as U.S. tax withholding certificates, self-certifications, etc., and collect additional information from client as needed to identify and support a FATCA status. Step 4 Validate documentation collected, determine if documentation conflicts with other documentation or information (e.g., Anti-Money Laundering documentation), and determine if indicia of U.S. status exist and cure. Step 5 Classify and record FATCA status of new accounts in on-boarding systems. Step 6 Going forward, monitor account for changes in circumstances which may change FATCA status, and satisfy record retention requirements. Presumption rules will be applied for undocumented accounts; generally, individuals will be presumed U.S., and entities will be presumed NPFFIs. 10

12 Agenda Page Agenda 1 Overview of FATCA, FATCA Registration and Recent Developments 2 Timeline 6 New and Preexisting Account Due Diligence Requirements 8 Withholding Requirements 11 Reporting Requirements 14 Intergovernmental Agreements and OECD CRS 16 Appendix 22 11

13 F O R E I I G N A C C C C O U N T T A X C O M P L I I A N C C E E A C T : C U R R E N T D E V E L O P M E N T S Withholding Requirements Regulatory Requirements for both Withholding Agents and PFFIs (see Timeline for effective dates) General Withholding Rule: Withholdable payments made to nonparticipating FFIs or recalcitrant accounts will be subject to 30% FATCA withholding tax. Strict rules are provided regarding refunds of tax. Effective Dates (see Timeline) Withholding on new accounts held by individuals commences July 1, 2014, subject to exceptions Withholding on any preexisting or new entity account documented as Non-Participating FFI begins July 1, 2014 Withholding on new entity accounts not documented with a compliant FATCA tax status begins January 1, 2015 Multiple effective dates for commencement of withholding depending on specific facts and transition rules Payor Exception for FFIs outside the U.S.: Withholding is deferred until January 1, 2017, where the payor FFI is: Not acting as an intermediary with respect to the payment, and Not acting as a flow-through entity with withholding responsibilities (e.g., partnership for U.S. tax purposes) FATCA withholdable payments must be identified. U.S. source payments only, unless passthru payment rules become effective after Generally limited to FDAP (fixed and determinable annual and periodic income), the types of payments customarily subject to U.S. withholding and/or reporting under current law, such as dividends and interest. U.S. source payments are expanded from current rules as defined by FATCA (e.g., bank deposit interest paid by non-u.s. branches). Regular current U.S. tax withholding plus FATCA withholding cannot exceed 30% (unless regular rate exceeds 30%). A PFFI can elect to have a US Withholding Agent (USWA) withhold FATCA withholding tax at a rate identified by the PFFI (e.g., where the PFFI is an intermediary). FATCA withholding overrides U.S. income tax treaty withholding reductions, however, the beneficial owner of the withheld payment can file an income tax return and reclaim the tax withheld in excess of the treaty rate. 12

14 F O R E I I G N A C C C C O U N T T A X C O M P L I I A N C C E E A C T : C U R R E N T D E V E L O P M E N T S Withholding Requirements (Cont.) Grandfathered Obligations A grandfathered obligation is generally a debt security (but not an equity security), loan or contract outstanding on June 30, The security, loan or contract must have a maturity date to constitute a grandfathered obligation. Payments otherwise withholdable under FATCA are exempt from withholding if paid pursuant to a grandfathered obligation. Any FATCA reporting requirements are unchanged A material modification of a security, loan or contract will cause it to lose its status as a grandfathered obligation. Withholding agents can rely on written statements by the issuer of the grandfathered obligation for grandfathered status and determination of whether a material modification has taken place. Special rules relating to grandfathered obligations include: - Payment relating to collateral posted to secure a grandfathered obligation is exempt from FATCA withholding as a payment with respect to a grandfathered obligation. - Obligations giving rise to withholdable payments under IRC Section 871(m) or foreign passthru payments will be grandfathered if outstanding on or before the date six months after a specified date to be determined by future Treasury Regulations. (Note certain payments under IRC Section 871(m) have had regulations issued in late 2013 and the six-month time period is running.) - Standby letters of credit and revolving credit facilities may be considered grandfathered obligations (if terms are adequately fixed) even if the drawdown occurs after June 30,

15 Agenda Page Agenda 1 Overview of FATCA,, FATCA Registration and Recent Developments 2 Timeline 6 New and Preexisting Account Due Diligence Requirements 8 Withholding Requirements 11 Reporting Requirements 14 Intergovernmental Agreements and OECD CRS 16 Appendix 22 14

16 F O R E I I G N A C C C C O U N T T A X C O M P L I I A N C C E E A C T : C U R R E N T D E V E L O P M E N T S Reporting Requirements Reporting Requirements for Withholding Agents and PFFIs See Timeline The first Form 8966 information report for U.S. accounts and other information reportable under FATCA will cover the 2014 calendar year and due March 31, 2015; this date can be automatically extended up to six months. - Most FATCA reporting of a USWA will be provided on Form 1042-S, due March 15, New FATCA annual reporting to the IRS includes select information for payees and accounts owned by U.S. persons and nonparticipating FFIs, and PFFIs recalcitrant accounts. Limited reporting in earlier years, expanded in later years (see Timeline) USWAs don t have recalcitrant accounts; accounts that are not fully or validly documented will be treated as undocumented and subject to presumption rules to determine a FATCA tax status Form 8966 (new): A final Form 8966 was released March 5, PFFIs and USWAs will report the following on Form 8966: PFFIs Only: Annual reporting of U.S. account holders PFFIs Only: Foreign reportable amounts paid to an NPFFI in 2015 and 2016 PFFIs Only: Reporting of payments to recalcitrant payees (tax year 2014 forward). PFFIs and USWAs: Reporting of specified substantial U.S. owners of passive Non-Financial Foreign Entities (NFFEs) PFFIs and USWAs: Reporting of specified U.S. owners of Owner-Documented FFIs Form 1042 / 1042-S: USWAs will report the following on Form 1042 /1042-S. The 2014 forms have been expanded to capture data relevant to FATCA. For countries who have entered into IGA, Model 1, annual reporting is provided to the local government (not IRS), with subsequent intergovernmental exchange of data to IRS. Due dates are expected to be similar to the IRS due dates. - Reporting will be provided on the FATCA schema; specifications have been released and posted on the IRS FATCA website. 15

17 Agenda Page Agenda 1 Overview of FATCA,, FATCA Registration and Recent Developments 2 Timeline 6 New and Preexisting Account Due Diligence Requirements 8 Withholding Requirements 11 Reporting Requirements 14 Intergovernmental Agreements and OECD CRS Appendix 22 16

18 F O R E I I G N A C C C C O U N T T A X C O M P L I I A N C C E E A C T : C U R R E N T D E V E L O P M E N T S Intergovernmental Agreements Model 1 Intergovernmental Agreements (IGAs) are bilateral agreements concluded between the U.S. and countries considered partner jurisdictions with the aim of improving international tax compliance and implementing FATCA. Please refer to the table on the following page for details of the countries that have entered into an IGA or are currently undertaking negotiations. FATCA will be enforced though local legislation as the IGA simply provides the formal framework for the implementation of the rules. Model 1 IGA plus Annex 2 Updated June 6, 2014 The Financial Institution (FI) registers with the IRS and commits to report information on reportable accounts annually to their local tax authority in line with the legislation set out by the partner jurisdiction. The partner jurisdiction will automatically exchange this information with the IRS. The FI should also provide its U.S. withholding agents with the amount of the FATCA withholdable income it receives allocable to its investors who are not FATCA compliant. Currently three versions of the Model 1 IGA have been released by the IRS (Link: Reciprocal Model 1A Agreement, Preexisting TIEA or DTC Nonreciprocal Model 1B Agreement, Preexisting TIEA or DTC Nonreciprocal Model 1B Agreement, No TIEA or DTC Final Regulations confirm Model 1 IGA definitions apply in place of FATCA definitions set out in the final regulations. FATCA registration may be required by a variety of foreign financial institutions and branches and in some circumstances by U.S. financial institution or branches. In particular, branches of U.S. financial institutions constituting Reporting Financial Institutions under a Model 1 FATCA Intergovernmental Agreement will have to register. 17

19 F O R E I I G N A C C C C O U N T T A X C O M P L I I A N C C E E A C T : C U R R E N T D E V E L O P M E N T S Intergovernmental Agreements Model 2 Model 2 IGA plus Annex 2 Updated June 6, 2014 FIs are required to register with the IRS and report information on reportable accounts annually, directly to the IRS. The partner jurisdiction may then share information on recalcitrant accounts with the IRS. Currently two versions of the Model 2 IGA have been released by the IRS (Link: Model 2 Agreement, Preexisting TIEA or DTC Model 2 Agreement, No TIEA or DTC A Reporting Financial Institution is required to obtain consent to report details of the account holder to the IRS on an annual basis, or where consent if not obtained, to report aggregate information on non-consenting accounts, upon request initiated by the IRS, to the Model 2 Tax Authority. 18

20 F O R E I I G N A C C C C O U N T T A X C O M P L I I A N C C E E A C T : C U R R E N T D E V E L O P M E N T S FATCA Intergovernmental Agreements (as of June 10, 2014) Signed IGA Countries Australia ( ) Belgium ( ) Canada ( ) Cayman Islands ( ) Costa Rica ( ) Denmark ( ) Estonia ( ) Finland ( ) France ( ) Germany ( ) Gibraltar ( ) Guernsey ( ) Hungary ( ) Honduras ( ) Ireland ( ) Isle of Man ( ) Italy ( ) Jamaica ( ) Jersey ( ) Liechtenstein ( ) Luxembourg ( ) Malta ( ) Mauritius ( ) Mexico ( ) Netherlands ( ) Norway ( ) Spain ( ) Slovenia ( ) United Kingdom ( ) Model 2 IGA Austria ( ) Bermuda ( ) Chile ( ) Japan ( ) Switzerland ( ) Countries which have consented to be treated as having an IGA Azerbaijan ( ) Bahamas ( ) Barbados ( ) Brazil ( ) British Virgin Islands ( ) Bulgaria ( ) Colombia ( ) Croatia ( ) Curacao ( ) Czech Republic ( ) Cyprus ( ) India ( ) Indonesia ( ) Israel ( ) Kosovo ( ) Kuwait ( ) Latvia ( ) Lithuania ( ) New Zealand ( ) Panama ( ) Peru ( ) Poland ( ) Portugal ( ) Qatar ( ) Romania ( ) Seychelles ( ) Singapore ( ) Slovak Republic ( ) South Africa ( ) South Korea ( ) Sweden ( ) Turkey ( ) Turkmenistan ( ) Turks and Caicos Islands ( ) United Arab Emirates ( ) Model 2 IGA Armenia ( ) Hong Kong (

21 OECD Multilateral Automatic Exchange of Information Overview & Updates The OECD published the Global Standard for the Automatic Exchange of Financial Information on February 13, The Global Standard was developed with strong support of the EU, G8, G20 and UN and is heavily based on Model 1 IGA (U.S. FATCA) On May 6, 2014 a Declaration on Automatic Exchange of Information in Tax Matters, which commits countries to implement the Global Standard, was endorsed by the 34 OECD members and other countries, including China. The Global Standard consists of: 1. Common Reporting Standard containing reporting and due diligence rules imposed on Financial Institutions; and 2. Competent Authority Agreement containing detailed rules on the exchange of information. OECD documents do not include any timelines, but it is expected Financial Institutions in countries adopting the standard will be required to undertake due diligence obligations in 2016 and begin reporting in Reportable information includes all types of investment income (e.g. interest, dividends, income from certain insurance contracts and similar types of income), account balances and sales proceeds from financial assets. Financial institutions required to report include banks, custodians, brokers, certain collective investment vehicles and certain insurance companies. Reportable accounts include accounts held by individuals and entities (including trusts and foundations); the standard includes a requirement to look through passive entities to report on individuals that ultimately control these entities. The Common Reporting Standard also includes due diligence procedures to be followed by Financial Institutions to identify reportable accounts and obtain accountholder information required to be reported. The Common Reporting Standard will require translation to domestic law whereas the Competent Authority Agreement can be executed within the existing legal framework: a) Article 26 of OECD Model Tax Convention; or b) Multilateral Convention on Mutual Administrative Assistance in Tax Matters, as amended in

22 OECD Multilateral Automatic Exchange of Information Key Differences between the OECD Standard and U.S. FATCA OECD Standard U.S. FATCA Fully reciprocal U.S. specificities have been removed Tax Residency Not fully reciprocal U.S. specific legal concepts (W8/W9s) U.S. Tax Residency and US Citizenship Investment Entity from a country which has not entered into the CRS will be classified as a Passive NFFE *** Investment Entities fall in the definition of Financial Institutions only ***Significant departure from US FATCA as it will require Financial Institutions resident in CRS countries to obtain information on controlling persons of any fund outside a CRS country that is an account holder Removal of the exemption for regularly traded investment entities (e.g. U.K. Investment Trusts and ETFs in countries adopting the CRS will be included) Removal of de minimis threshold for new accounts all accounts, regardless of size, will be subject to reporting. Pre-existing Lower Value Accounts Due Diligence: Financial Institutions will be able to rely on the residence address on record as a proxy of tax residence of pre-existing account holders. Documentary evidence does not include documents listed in attachments to Qualified Intermediary Agreements with the U.S. Exemption from the definition of financial account for interests in funds regularly traded on a stock exchange. New individual accounts below U.S. $50,000 are not required to be reviewed, identified or reported. Preexisting Lower Value Accounts Due Diligence: Financial Institutions will need to perform electronic checks on available records to determine the accountholder s status. Documentary evidence includes documents listed in attachments to Qualified Intermediary Agreements with the U.S. 21

23 Agenda Page Agenda 1 Overview of FATCA, FATCA Registration and Recent Developments 2 Timeline 6 New and Preexisting Account Due Diligence Requirements 8 Withholding Requirements 11 Reporting Requirements 14 Intergovernmental Agreements and OECD CRS 16 Appendix 22 22

24 F O R E I I G N A C C C C O U N T T A X C O M P L I I A N C C E E A C T : C U R R E N T D E V E L O P M E N T S Tax Forms - New U.S. Tax Certification, Reporting and Registration Forms Form Intended usage Notes Form W-9 Form W-8BEN (individuals only) Request for U.S. taxpayer identification number Certificate of foreign status of beneficial owner for U.S. tax withholding (Individuals) Final version released August 29, 2013 Final Requestor instructions released Final version released March 3, 2014 Instructions released March 3, 2014 Form W-8BEN-E (entities only) Certificate of foreign status of beneficial owner for U.S. tax withholding (Entities) Final version released March 28, 2014 Instructions not yet released Form W-8ECI Form W-8EXP Certificate of foreign person s claim that income is effectively connected with the conduct of a trade or business in the U.S. Certificate of foreign government or other foreign organization for U.S. tax withholding Final version released March 3, 2014 Instructions released March 4, 2014 Final version released April 16, 2014 Instructions released May 1, 2014 Form W-8IMY Certificate of foreign intermediary, foreign flow-through entity, or certain U.S. branches for U.S. tax withholding Final version released April 29, 2014 Instructions not yet released Form 8966 FATCA report (primary information reporting form for PFFIs) Final version released March 5, 2014 To be used by FFIs and withholding agents To report all financial account information Form 8957 FATCA registration (in lieu of online Registration) Final version released August 19, 2013 Form 1042 Form 1042-S Annual Withholding Tax Return for U.S. Source Income of Foreign Persons Final Form 1042 released March 21, 2014 Instructions to Form 1042 released May 2, 2014 Final Form 1042-S released April 2, 2014 Foreign Person s U.S. Source Income Subject to Withholding To include all the information to be reported by withholding agents under both FATCA and current reporting rules 23

25 F O R E I I G N A C C C C O U N T T A X C O M P L I I A N C C E E A C T : C U R R E N T D E V E L O P M E N T S IRS Circular 230 Disclosure: JPMorgan Chase & Company and its affiliates do not provide tax advice. Accordingly any discussion of U.S. tax matters contained herein (including any attachments) is not intended or written to be used, and cannot be used, in the connection with the promotion, marketing or recommendation by anyone unaffiliated with JPMorgan Chase & Co. of any of the matters addressed herein or for the avoidance of U.S. tax related penalties. This document is for informational purposes only, and the information contained herein may change at any time without previous notice or communication. It is intended neither to influence your investment decisions nor to amend or supplement any agreement governing your relations with J.P. Morgan. J.P. Morgan shall not be liable for any damages or costs whatsoever arising out of or in any way connected with your use of the mentioned information. J.P. Morgan does not warrant or assume any legal liability or responsibility for the accuracy, completeness, or usefulness of any information herein provided, and gives no representations whatsoever as to the legal, regulatory, financial, tax or accounting implications of the matter in this document JPMorgan Chase & Co. All rights reserved This presentation was prepared exclusively for the benefit and internal use of the J.P. Morgan client to whom it is directly addressed and delivered (including such client s subsidiaries, the Company ) in order to assist the Company in evaluating, on a preliminary basis, certain products or services that may be provided by J.P. Morgan. This presentation contains information which is confidential and proprietary to J.P. Morgan, which may only be used in order to evaluate the products and services described herein and may not be disclosed to any other person. In preparing this presentation, we have relied upon and assumed, without independent verification, the accuracy and completeness of all information available from public sources or which was provided to us by or on behalf of the Company or which was otherwise reviewed by us. This presentation is for discussion purposes only and is incomplete without reference to, and should be viewed solely in conjunction with, the oral briefing provided by J.P. Morgan. Neither this presentation nor any of its contents may be used for any other purpose without the prior written consent of J.P. Morgan. J.P. Morgan makes no representations as to the legal, regulatory, tax or accounting implications of the matters referred to in this presentation. Notwithstanding anything in this presentation to the contrary, the statements in this presentation are not intended to be legally binding. Any products, services, terms or other matters described in this presentation (other than in respect of confidentiality) are subject to the terms of separate legally binding documentation and/or are subject to change without notice. Neither J.P. Morgan nor any of its directors, officers, employees or agents shall incur any responsibility or liability whatsoever to the Company or any other party in respect of the contents of this presentation or any matters referred to in, or discussed as a result of, this document. All services are subject to applicable laws and regulations and service terms. Not all products and services are available in all geographic areas. Eligibility for particular products and services is subject to final determination by J.P. Morgan and or its affiliates/subsidiaries. J.P. Morgan is a marketing name for the Investor Services businesses of JPMorgan Chase Bank, N.A. and its subsidiaries worldwide. J.P. Morgan is licensed under U.S. Pat Nos. 5,910,988 and 6,032, JPMorgan Chase & Co. All rights reserved. JPMorgan Chase Bank, N.A. Member FDIC. 24