In general, subject to the discussion below under the headings «Information Reporting and Backup Withholding» and «Foreign Accounts,» distributions, if any, paid
on our common stock to a Non-U.S. Holder (to the extent paid out of our current or accumulated earnings and
profits, as determined under U.S. federal income tax principles) will constitute dividends and be subject to U.S. withholding tax at a rate equal to 30 % of the
gross amount of the dividend, or a lower rate prescribed by an applicable income tax treaty, unless the dividends are effectively connected with a
trade or business carried
on by the Non-U.S. Holder within the United States.