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The Bank of Tokyo-Mitsubishi UFJ, Ltd. Global Securities Services Division

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The Bank of Tokyo-Mitsubishi UFJ, Ltd. Global Securities Services Division The Bank of Tokyo-Mitsubishi UFJ, Ltd. Global Securities Services Division CCuussttooddyy NNeewwssffllaasshh March 6th, 2006 List of Investment Banks exempt from taxation for interest under the Japan-US tax treaty =============================================================================== Category Tax Issues Summary Japan’s National Tax Agency, today on its homepage, released a list of Investment Banks exempt from taxation for interest under the Japan-US tax treaty. Impact The list identifies and confirms Investment Banks to enjoy tax relief. Action Listed clients and clients with listed underlying customers should follow tax reporting procedures, as required. Please contact us is such case. =============================================================================== Japan’s National Tax Agency, today on its homepage, released a list of investment banks exempt from taxation for interest under the Japan-US tax treaty. The list contains twenty-five US parties, which were given notice by the US authorities, to benefit from provisions under the Japan-US tax treaty, and was drawn up in accordance with the “memorandum of agreement between relevant authorities”. On a separate list, there were also two Japanese entities given the same notice by the Japanese authorities. The memorandum of agreement, signed on December 27th, 2005 following discussions among the Japan and US tax authorities, was exchanged as a practical guideline with regards to interest where an investment bank is the beneficial owner. Article 11.3 of the Japan-US tax treaty (“Convention between the Government of Japan and the Government of the United States of America for Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income”), which became effective on March 30th, 2004, states as follows: …interest arising in a Contracting State shall be taxable only in the other contracting state if: …………………. (c) The interest is beneficially owned by a resident of that other Contracting State that is either: (i) a bank (including an investment bank); (ii) an insurance company; (iii) a registered securities dealer; or ……………… ======================================================================== The information contained herein has been derived from several sources believed to be reliable at the time of publication. Although having made every effort to ensure the accuracy of the contents, The Bank of Tokyo-Mitsubishi UFJ, Ltd. does not assume any liability for losses either direct or consequential caused by the use of this information. Copyright 2006 The Bank of Tokyo-Mitsubishi UFJ, Ltd. Page 1 of 2 The Bank of Tokyo-Mitsubishi UFJ, Ltd. Global Securities Services Division List of entities given notice by the US authorities to benefit from provisions under the Japan-US tax treaty The Bear Stearns Companies Inc. J.P. Morgan Chase & Co. Bear Stearns Corporate Lending Inc. J.P. Morgan International Finance Limited Bear Stearns Investment Products Inc. Lehman Brothers Holdings Inc. Bear Stearns Forex Inc. Merrill Lynch & Co., Inc. Citigroup Financial Products Inc. Merrill Lynch, Pierce, Fenner & Smith Inc. Citigroup Global Markets Holdings Inc. Merrill Lynch Capital Corporation Citigroup Overseas Investment Corporation Merrill Lynch Capital Services, Inc. Citigroup Funding Inc. Merrill Lynch Government Securities, Inc. Credit Suisse Holdings (USA), Inc. Merrill Lynch Mortgage Capital, Inc.; Credit Suisse (USA), Inc. Merrill Lynch Professional Clearing Corporation Credit Suisse Financial Corporation Merrill Lynch International , Inc. Column Financial, Inc. Merrill Lynch International Holdings, Inc. DLJ Mortgage Capital, Inc. Merrill Lynch Group, Inc. DLJ Real Estate Capital Partners, Inc. Morgan Stanley Credit Suisse Premium Finance LLC Morgan Stanley International Inc. The Goldman Sachs Group, Inc. Morgan Stanley International Holdings, Inc Goldman, Sachs & Co. Morgan Stanley Senior Funding Inc. Goldman Sachs Mortgage Corporation Morgan Stanley Asset Funding Inc. William Street Commitment Corporation Morgan Stanley Capital Group Inc. William Street Credit Corporation Morgan Stanley Capital Service Inc. William Street Funding Corporation Morgan Stanley Investment Management Inc. Goldman Sachs Credit Partners L.P. Morgan Stanley Principle Funding Inc. Goldman Sachs Capital Markets, L.P. Should you have any inquires, please feel free to contact us. Best regards, Global Securities Services Division / The Bank of Tokyo-Mitsubishi UFJ, Ltd. Past Newsflash issues are available on the BTMU Yen Custody Websit e; http://www.bk.mufg.jp/custody/. This site is dedicated to our clients, and accessible only with “ID” and “Password”. Should you require them, please contact us. ======================================================================== The information contained herein has been derived from several sources believed to be reliable at the time of publication. Although having made every effort to ensure the accuracy of the contents, The Bank of Tokyo-Mitsubishi UFJ, Ltd. does not assume any liability for losses either direct or consequential caused by the use of this information. Copyright 2006 The Bank of Tokyo-Mitsubishi UFJ, Ltd. Page 2 of 2.
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