The document outlines the potential returns and risks associated with certain investment notes linked to the performance of the Brazilian Real against 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 Reference Currency Return is greater than 0% and a 28.50% return if greater than 3%. If the return is less than the Barrier Level of -15%, investors may lose principal. The tax treatment is uncertain, with potential for ordinary income or capital gain/loss treatment under Section 988 of the Internal Revenue Code.
doj/DataSet10/EFTA01450397.pdf
{"key_people":["Morrison & Foerster LLP"],"document_type":"financial","key_locations":["U.S."],"document_subtype":"investment notes","key_organizations":["Internal Revenue Service (IRS)"],"reference_numbers":["Section 988","Section 1256","Section 1092"]}