Form S-I Table of Contrail will constitute a return of capital and first be applied against and reduce a non-U.S. Holder's adjusted tax basis in its common stock. but not below zero. Any excess will be treated as capital gain and will be treated as described below under "Gain on Disposition of Common Stock." Dividends paid to a non-U.S. Holder of our common stock generally will be subject to withholding of United States federal income tax at a 30% rate or such lower rate as may be specified by an applicable income tax treaty. However, dividends that are effectively connected with the conduct of a trade or business by the non-U.S. Holder within the United States (and, if required by an applicable income tax treaty. are attributable to a United States permanent establishment) arc not subject to the withholding tax, provided certain certification and disclosure requirements ate satisfied. Instead, such dividends arc subject to United States federal income tax on a net income basis generally in the same manner as if the non- U.S. Holder were a United States person as defined under the Code. Any such effectively connected dividends receives' by a foreign corporation may be subject to an additional "branch profits tax" at a 30% rate or such lower rate as may be specified by an applicable income tax treaty. A non-U.S. Holder of our common stock who wishes to claim the benefit of an applicable income tax treaty rate and avoid backup withholding, as discussed below, for dividends will be required (a) to complete the applicable Internal Revenue Service Form W-8 and certify under penalty of perjury that such holder is not a United States person as defined under the Code and is eligible for treaty benefits or (b) if our common stock is held through certain foreign intermediaries. to satisfy the relevant certification requirements of applicable United States Treasurys regulations. Special certification and other requirements apply to certain non-U.S. Holders that a