What are the tax consequences of accepting or not accepting the Offer?

This document contains a general summary of the terms of the Offer, and it should not be relied upon for legal, financial or tax advice.  The tax consequences of participating or not participating in the Offer may vary according to your individual circumstances, and the tax treatment of this Offer is uncertain.  SAFT holders may recognize income for income tax purposes as a result of the Offer. Therefore, you should review the tax consequences of participating or not participating in the Offer with your legal, financial and tax advisor(s) before deciding whether to accept the Offer.