You should read the section entitled "Material United States Federal Income Tax Considerations" in the accompanying
product supplement. The preceding discussion, when read in combination with that section, constitutes the full
opinion of Davis Polk & Wardwell LLP regarding the material U.S. federal tax consequences of owning and disposing
of the securities.
You should also consult your tax advisor regarding all aspects of the U.S. federal income and estate tax
consequences of an investment in the securities and any tax consequences arising under the laws of any state, local
or non-U.S. taxing jurisdiction.
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