or the Post-Offer Reorganization and in particular, does not address many of die tax considerations applicable to shareholders that may be subject to special tax rules, including, without limitation: banks, certain financial institutions or insurance companies; real estate investment trusts. regulated investment companies or grantor trusts; dealers or traders in securities, commodities or currencies; tax-exempt entities; certain former citizens or long-term residents of the United States; persons that received Shares as compensation for the performance of services; persons that hold Shares as part of a "hedging." "integrated." or "conversion" transaction or as a position in a "straddle" for U.S. federal income tax purposes; partnerships (including entities classified as partnerships for U.S. federal income tax purposes) or other pass-through entities, or holders that hold Shares through such an entity: S-corporations; persons whose functional currency is not the U.S. dollar; persons that own directly. indirectly, or through attribution 10% or more of the voting power or value of the outstanding Shares; or persons holding Shares in connection with a trade or business conducted outside the United States; controlled foreign corporations within the meaning of Section 957 of the Code; or passive foreign investment companies within the meaning of Section 1297 of the Code ("PFIC"). Moreover, this summary does not address the U.S. federal estate, gift. Medicare. alternative minimum tax, and any other applicable non-income tax laws. or any applicable state, local or non-U.S. tax laws. For purposes of this summary, the term "U.S. Holder" means a beneficial owner of Shares that, for US. federal income tax purposes. is (a) an individual who is a citizen or resident of the United States: (b) a corporation, or an entity treated as a corporation for U.S. federal income tax purposes, created or organized under the laws of die United States, or of any state or the