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Depositary Receipts Market Updates

September 2013

• Withholding Tax Overview • ESP Designated Intermediaries • Depositary Reporting • Market Updates • Process Updates • Q&A • Contact Information Overview

Global Equity Investment Income: Dividend Withholding Tax Recovery

Foreign ORDs and ADRs Dividend Event Occurs 100% Invests $$$

US Domiciled Taxpayer, Endowment or Pension And Other Jurisdictions

65%-85% No Reclaim of Withholding

*Only at this point in the process are fees collected

85%-100% With Reclaim of Withholding

But Endowments and Pensions are Exempt!

Foreign Tax Authority 25%-35% Withheld

ESP Designated Intermediaries

ESP Reports

• Research & reconcile all outstanding claims • Lists recent payments • Link to the beneficial owner breakdown • Email notification when payment is made • Rates, ratios, and relevant dates (ORD Pay Date) for completing tax forms in local terms and ensuring accurate information • Lists recent rejections and reasons • Email notification when a claim is rejected • Expedites responses by sending the inquiries directly to the correct GlobeTax representative(s) • Provides a tool for managers to ensure that events are not missed and maximum potential refunds are realized © 2013 Globe Tax Services Inc.

South Korea

• • Additional data elements ― ― ― Record dates as of December 2012 Full beneficial owner address Tax Identification Numbers (TINs) OIVs / OPCIVs — — — Must provide Form 29-13 / Annex to Form 29-13 Self-Certification with Korean MoSF audit possibilities Depositaries and the local agents will not determine if an account is an OIV or OPCIV 7 © 2013 Globe Tax Services Inc.

Japan (2014 – expected)

• • • Reduced withholding rates to expire Dec. 31, 2013 ― Withholding will increase to 15.315% ― U.S. Treaty reduces this to 10% Required documentation ― IRS Form 6166 per beneficial owner (for all entity types) Depositaries in discussions with Japanese custodians regarding documentation requirements 8 © 2013 Globe Tax Services Inc.

Depositary Process Changes

• • • • Belgium — Eliminated exemption for US Charities Sweden — Revised documentation for foreign non-UCITs funds to receive exemption from withholding tax Switzerland — US RICs now must be disclosed at entity level and provide certain attestations if claiming over CHF 100,000 in treaty benefits Kazakhstan – not yet in force ― Issues likely to default to 20% withholding with disclosure requirements to obtain the 15% withholding rate 9 © 2013 Globe Tax Services Inc.

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EDS Assist

® The relief at source allocation tool Uses – Instruct on EDS ( Elective Dividend Service ) elections Users – DTC Participants only (and their clients) Metrics – EDS eligible securities – Currently 19 markets Delivery – Daily via Comerica’s system(s) Features – Daily delivery from GlobeTax for all elections • • • Specific instructions for each ‘segment’ of BOs (e.g. Exempt, Favorable, Unfavorable) ensuring all clients receive maximum benefit – Document collection support 6166s, Letters of Exemption, applicable renewals – Payment Mapping File Automates payments for each dividend event to all holders DTC Participant • EDS Allocations • Payment mapping • Security Data • Ben Owner Data GlobeTax 10 © 2013 Globe Tax Services Inc.

Securities Class Actions Services

GlobeTax files claims for our clients who are eligible to share in settlement funds due to corporate misstatements or omissions.

Value added: • Asset recovery and protection • Positioned to benefit from upcoming mega settlements • Interests aligned with client (no recovery – no fee) • Outsourced service ensures focus on claiming legal entitlements freeing you to concentrate on your business 11 © 2013 Globe Tax Services Inc.

Securities Claims Service Summary

• Cases Covered ─ Securities Class Actions ─ Insider trading ─ Government disgorgements and restitutions ─ SEC fines ─ Dodd-Frank whistleblower cases • Securities Class Action Services ─ Case data monitoring ─ Client trade data qualifying analysis ─ Claims processing, filing, and monitoring through payment • Additional Features ─ Sub-account processing ─ Quarterly client reporting ─ Contingency fee based on funds recovered ─ Dedicated and confidential service 12 © 2013 Globe Tax Services Inc.

Brett Lewis –

Director [email protected]

Gregg Lewis –

Vice President [email protected]

William Treut

- Managing Director [email protected]

Harold Shapero –

Managing Director [email protected]

Len Lipton –

Managing Director [email protected]

Jose Bisono –

Managing Director & COO [email protected]

Telephone: +1 (212) 747-9100 New York London Madrid

Contact Information

Milan Sydney Hong Kong

Statutory Rate Changes – 2013

• Chile from 20.245% to 18.75%* • Czech Republic from 15% to 35% • Morocco from 10% to 15% • Portugal from 30% to 35% • Slovenia from 20% to 25% • Belgium eliminated exemption for Charities / Foundations (

including US entities

) *

Due to change in imputation rate not statutory rate change