The document outlines the purchase considerations for investment notes linked to the Brazilian Real versus the U.S. Dollar. It details the 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 a Section 988 election to treat gains or losses as capital gains or losses.
documents/vol00010-efta01344643-pdf.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"]}