Prospectus supplement US007924AH66 - Aegon
Prospectus supplement US007924AH66 - Aegon
Prospectus supplement US007924AH66 - Aegon
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TAXATION IN THE UNITED STATES<br />
This discussion is the opinion of Allen & Overy LLP insofar as it relates to matters of U.S. federal<br />
income tax law and describes certain material U.S. federal income tax consequences to beneficial<br />
holders of securities. This section addresses only the U.S. federal income tax considerations for holders<br />
that acquire the securities at their original issuance and hold the securities as capital assets. This<br />
section does not address all U.S. federal income tax matters that may be relevant to a particular<br />
prospective holder. Each prospective investor should consult a professional tax advisor with respect to<br />
the tax consequences of an investment in the securities. This section does not address tax<br />
considerations applicable to a holder of security that may be subject to special tax rules including,<br />
without limitation, the following:<br />
• financial institutions;<br />
• insurance companies;<br />
• dealers or traders in securities or currencies;<br />
• tax-exempt entities;<br />
• regulated investment companies;<br />
• persons that will hold the securities as part of a ‘‘hedging’’ or ‘‘conversion’’ transaction or as a<br />
position in a ‘‘straddle’’ for U.S. federal income tax purposes;<br />
• persons who hold the securities through partnerships or other pass-through entities;<br />
• holders that own (or are deemed to own) 10% or more of the voting shares of the relevant<br />
issuer or guarantor; and<br />
• holders that have a ‘‘functional currency’’ other than the U.S. dollar.<br />
Further, this section does not address alternative minimum tax consequences or the indirect effects<br />
on the holders of equity interests in a holder of security.<br />
This discussion does not cover every type of security, such as warrants, units or purchase contracts,<br />
that may be issued under this prospectus. If we intend to issue a security of a type not described in this<br />
section, or if there are otherwise special tax consequences with respect to the security that are not<br />
covered herein, additional tax information will be provided in the prospectus <strong>supplement</strong> or pricing<br />
<strong>supplement</strong> for the applicable security.<br />
This section is based on the U.S. Internal Revenue Code of 1986, as amended (the ‘‘Code’’), U.S.<br />
Treasury regulations (the ‘‘Treasury regulations’’) and judicial and administrative interpretations, in<br />
each case as in effect and available on the date of this prospectus. All of the foregoing are subject to<br />
change, which change could apply retroactively and could affect the tax consequences described below.<br />
Each prospective investor should consult its own tax advisor with respect to the U.S. federal, state,<br />
local and foreign tax consequences of acquiring, owning or disposing of the securities.<br />
For the purposes of this section, a ‘‘U.S. holder’’ is a beneficial owner of securities that is, for U.S.<br />
federal income tax purposes:<br />
• a citizen or resident of the United States;<br />
• a corporation, or other entity that is treated as a corporation for U.S. federal income tax<br />
purposes, created or organized in or under the laws of the United States or any state of the<br />
United States (including the District of Columbia);<br />
• an estate, the income of which is subject to U.S. federal income taxation regardless of its source;<br />
or<br />
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