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Friday, July 29, 2011 8:09:24 AM
The exchange of outstanding notes for exchange notes in the exchange offer will not be a taxable exchange for U.S. federal income tax purposes and, accordingly, for such purposes a U.S. holder will not recognize any taxable gain or loss as a result of such exchange and will have the same tax basis and holding period in the exchange notes (and, in the case of a U.S. holder that paid pre-issuance accrued interest in connection with the U.S. holder’s purchase of the outstanding notes in their original offering, the same amount of pre-issuance accrued interest in the exchange notes) as it had in the outstanding notes immediately before the exchange.
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