The document outlines the potential returns and risks associated with investment notes linked to the Brazilian Real versus the U.S. Dollar. It discusses appreciation potential, loss of principal, exposure to currency fluctuations, and tax treatment. The notes offer a 5% return if the currency return is greater than 0% and a 28.50% return if greater than 3%. If the currency return is below the barrier level of -15%, investors may lose principal. Tax treatment is uncertain, with potential for ordinary income or capital gain/loss depending on elections made under Section 988 of the Internal Revenue Code.
doj/DataSet10/EFTA01450384.pdf
{"title":"Selected Purchase Considerations","key_people":["Morrison & Foerster LLP"],"document_date":"2013-10-29","document_type":"financial","key_locations":["U.S.","Brazil"],"document_subtype":"investment notes","key_organizations":["Internal Revenue Service","U.S. federal income tax"],"reference_numbers":["Section 988","Section 1256","Section 1092"]}