What makes Equity- and Commodity-linked ELEMENTS a tax-efficient investment option?
ELEMENTS are intended to provide a tax-efficient means to invest. Index mutual funds and exchange-traded funds (ETFs) are often required to make yearly taxable income and capital gains distributions to shareholders. In contrast, under the intended tax treatment of Equity- and Commodity-linked ELEMENTS, investors should only realize capital gains or losses upon the sale, maturity, or repurchase by the issuer of their Equity- and Commodity-linked ELEMENTS. There is no direct authority governing the tax treatment of Equity- and Commodity-linked ELEMENTS, and there can be no assurance that the IRS or a court will agree with the intended tax treatment. No assurance can be given that future tax legislation, regulations or other guidance may not change the tax treatment of ELEMENTS. Even if the tax treatment of ELEMENTS is changed only on a prospective basis, that could affect our ability to issue additional ELEMENTS under an existing pricing supplement, which could affect liquidity for ELEME
