What do you mean? It's not a offer, only a exchange Exchange of Outstanding Notes for Exchange Notes
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.