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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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