the dividends are effectively connected with a trade or business carried on by the non-U.S. holder within the United States (and, if an income tax treaty applies, are attributable to a permanent establishment of the non-U.S. holder within the United States). A distribution will constitute a dividend for V.S. federal income tax purposes to the extent of our current or accumulated earnings and profits as determined for U.S. federal income tax purposes. Any distribution not constituting a dividend will be treated as first reducing the adjusted basis in the non-U. S. holders shares of our common stock and, to the extent it exceeds the adjusted basis in the non-U.S. holders shares of our common stock, as gain from the sale or exchange of such shares. Dividends effectively connected with a U.S. trade or business (and, if an income tax treaty applies, attnbutable to a U.S. permanent establishment) of a non- U.S. holder generally will not be subject to U.S. withholding tax if the non-U.S. holder complies with applicable certification and disclosure requirements. Instead, such dividends generally will be subject to U.S. federal income tax on a net income basis, in the same manner as if the non-U.S. holder were a resident of the United States. A non-U.S. holder that is a corporation may be subject to an additional "branch profits tax" at a rate of 30% (or such lower rate as may be specified by an applicable income tax treaty) on its "effectively connected earnings and profits," subject to certain adjustments. Gain on sale or other disposition of our common stock In general, a non-U.S. holder will not be subject to U.S. federal income or, subject to the discussion below under the heading "Information Reporting and Backup Wthholding" and 'Foreign Account Tax Compliance Act." withholding tax on any gain realized upon the sale or other disposition of our common stock unless: • the gain is effectively connected with a trade or business carried on by the non-U.S. hold