This
discussion also does not consider any specific facts or
circumstances that may be relevant to holders subject to
special rules under the U.S. federal income tax laws, including, without limitation, certain former citizens or long - term residents
of the United States, partnerships or other pass - through entities, real estate investment trusts, regulated investment companies, «controlled foreign corporations,» «passive foreign investment companies,» corporations that accumulate earnings to avoid U.S. federal income tax, banks, financial institutions, investment funds, insurance companies, brokers, dealers or traders in securities, commodities or currencies, tax - exempt organizations, tax - qualified retirement plans, persons subject to the alternative minimum tax, persons that own, or have owned, actually or constructively, more than 5 %
of our common stock and persons holding our common stock as part
of a hedging or conversion transaction or straddle, or a constructive sale, or other risk reduction strategy.
In addition, this
discussion does not address the impact
of the Medicare contribution tax on net investment income or tax considerations applicable to an investor's particular
circumstances or to investors that may be subject to
special tax rules, including, without limitation:
There is, however, a narrow «
special circumstances» exception to employees» rights that employers in the hospitality industry may seek to utilize to prohibit certain
discussions in front
of customers.
Instruction should include face - to - face
discussions by course participants and faculty; i.e., on - line instruction may be a component
of instruction in responsible conduct
of research but is not sufficient to meet the NIH requirement for such instruction, except in
special or unusual
circumstances.