Ask the Scholar

Document scope · 1 page
doc
Scholar
Ask about this object, its catalog metadata, its source description, or the page inventory. For page-specific OCR and visual context, open one of the page chats.

Scholar Source Context

Document identity
localId
134607235
label
Foreign Earnings Repatriation Proposal
core
doc
dtoType
document
pageCount
1
Source metadata
Source extras
naId
134607235
levelOfDescription
fileUnit
recordType
description
ocrSource
nara-archive
Single page context
seq
1
pageIndex
0
type
document
mediaId
17715c952d485bf9
ocrText
2015-0056-F [ ] Tuesday, April 05, 2016 FOIA Marker This is not a textual record. This FOIA Marker indicates that material has been removed during FOIA processing by George W. Bush Presidential Library staff. Council of Economic Advisers Swagel, Phillip - Subject Files Location or NARA Number: FRC ID: OA Number: Stack: Row: Sect. Shelf: Pos.: Hollinger ID: W 30 16 1 2 5861 18796 4372 4539 Folder Title Foreign Earnings Repatriation Proposal 5/19/03 INVEST IN THE USA PROPOSAL (S. 596) INCLUDED IN THE SENATE TAX RELIEF RECONCILIATION BILL (S. 1056) Current Law Under international tax principles, primary jurisdiction to tax income is the country where the business operates rather than the country where the business is based. Many countries (but not the U.S.) exclude foreign dividends from domestic taxation, which encourages the reinvestment of surplus foreign earnings back home into these countries. In the U.S., by contrast, companies are required to pay tax on foreign subsidiary earnings when the earnings are brought back to the U.S., to the extent of any shortfall in the income tax paid abroad and the 35-percent U.S. tax rate. As a result, foreign earnings of U.S.-based companies have accumulated abroad because, if they are reinvested in U.S. operations, the U.S. will collect up to a 35% tax. This aspect of U.S. tax law is a significant incentive to leave foreign earnings offshore. As a result, less desirable foreign investments are frequently more profitable for U.S. companies despite better investment opportunities in the United States. Pool of Accumulated foreign earnings abroad Based on an examination of the financial statements of the S&P 500, JP Morgan estimates that the pool of foreign earnings that has accumulated over the years and is eligible to be brought to the United States is about $500 billion, an estimate that is consistent with an examination of IRS tax data. Much of this accumulated foreign investment is designated for financial reporting purposes as permanently invested overseas and thus there is no expectation of any U.S. tax being paid in the future. Invest in the U.S.A. proposal included in S. 1056 The Senate-passed Jobs and Economic Growth tax bill includes a provision originally introduced as S. 596 by Senators Ensign, Boxer, Smith, Bayh, Allen and Enzi. It was adopted by voice vote after a 75-25 vote adopting a procedural motion on the floor by Senator Ensign to consider it. All the Republicans and half the Democrats voted in favor. Similar bipartisan proposals have been introduced in the House. Proposed Change For a one-year period, the 35% tax rate on transfers to the U.S. of foreign corporate earnings would be replaced with a 5.25% toll charge on transfers in excess of the company's historical average. No foreign tax credit would be allowed for 85% of the foreign taxes associated with dividends and other transfers qualifying for the 5.25% toll charge. The 5.25% toll charge could not be reduced by net operating losses. 1 5/19/03 To encourage immediate economic stimulus, the reduced rate of tax would be effective for the first taxable year ending 120 days or more after the date of enactment. Thus, for example, if the bill is enacted on May 25, 2003 and the electing taxpayer is on a calendar year, the bill will apply to the taxpayer's taxable year ending December 31, 2003. The effective date is structured so as not to encourage taxpayers to suppress current dividends before it becomes effective. Estimated additional U.S. investment from accumulated foreign earnings The Joint Committee on Taxation estimates that the change would bring into the United States an additional $140 billion of accumulated foreign earnings. JP Morgan performed an independent study of S&P 500 financial data for its investors and estimated the amount to be about $300 billion. JP Morgan advises that the proposal will result in a 2-3% cumulative increase in domestic investment during 2003-04, a one percentage point cumulative increase in GDP growth over 2003-04 and a 3% reduction in nonfinancial corporate debt that strengthens corporate balance sheets and lowers corporate bond rates. A PwC survey of just 14 companies showed that the additional U.S. reinvestment would increase domestic investment in plant, equipment, R&D, and pension plans depleted by decline in the stock market; reduce domestic debt loads; increase dividends that could be productively redeployed; and raise equity market valuations by increasing funds available for share repurchases. Uses of Additional Dollars Brought to the U.S. as a Result of S. 596 PricewaterhouseCoopers Survey of 14 Companies (4/11/03) Percent of foreign subsidiaries' accumulated untaxed earnings at end of 54% 2002 that would be distributed to the U.S. as a result of S. 596 Additional distributions to U.S. in the survey (note that this is just the amount in excess of the base amount of normal distributions) $47,045,799,109 Use of additional distributions shown above - 1. Additional investment in U.S. plant, equipment, inventory, land or working capital 32% 2. Additional U.S. debt reduction 1 32% 3. Additional repurchase of company stock 12% 4. Additional portfolio investment in the U.S. 9% 5. Additional/accelerated contributions to U.S. pension plans 4% 6. Additional dividends to shareholders 1% 7. Additional compensation to corporate officers 0% 8. Additional compensation to other than corporate officers 0% 9. Other investments in the U.S. (identified by respondents as additional expenditures on R&D, business start-ups, and business & technology acquisitions) 10% Total 100% 1 The additional debt reduction is reported by some as a first step prior to a determination as to how best to use resources that were previously invested abroad. For others, the U.S. debt reduction is the intended improvement in the U.S. operations (to stabilize or improve debt ratings). 2 5/19/03 Revenue estimate. The Joint Committee on Taxation estimates that S. 596 will increase tax receipts by about $3.8 billion in the first year, and reduce net revenue by $3.8 over the 10-year budget period. PricewaterhouseCoopers. JP Morgan and a statement by House Ways and Means Committee Chairman Thomas at a hearing disagree with the JCT estimate. PwC and JP Morgan both estimate that the proposal increases federal receipts over the 10-year period. 3 JPMorgan Economic & Policy Research JPMorgan Securities Inc. May 1, 2003 Special report Introducing the Homeland Investment Act A tax change is proposed that temporarily reduces obstacles to repatri- ating accumulated foreign earnings of US corporations Legislation to produce results; repatriation estimated at $300 billion Survey suggests that firms would use funds for varied purposes; shor- ing up corporate finances is the top priority Estimated increase in business spending to lift GDP growth 0.5% Budget impact is negligible Introduction Amid the current flurry of activity on US tax policy, it is easy to neglect the Homeland Investment Act. This tax proposal, which has bipartisan support, would remove many of the tax obstacles that inhibit repatriation of foreign earn- ings by US corporations. The intention of this legislation is to make it less costly to repatriate earnings that might be used for investment spending and hiring in the United States. However, there is little analysis available that bears on the likely impact of this legislation. To fill this gap, this special report draws on existing company infor- mation and provides new survey material to give rough guidance as to the poten- tial effects of the Homeland Investment Act. The analysis suggests that there is a large pool of reinvested foreign earnings that would be repatriated if this legisla- tion were passed. JPMorgan estimates that the gross flow that would result from the passage of the pending legislation is roughly $300 billion. This number is more than twice the estimate of the Joint Committee on Taxation made in 2001. A survey of firms suggests that this money would be put to varied use. Shoring up Anne Swope balance sheets would be a central priority. JPMorgan estimates suggest that the (1-212) 834-7566 legislation would lead to a roughly 3% reduction in nonfinancial corporate debt. [email protected] An important part of the funds would be used to increase business activity. Esti- JPMorgan Chase Bank mates suggest a 2-3% increase in capital spending over two years, during which Bruce Kasman the GDP level would likely be boosted by roughly one-half of a percentage point. (1-212) 834-5515 The impact of the legislation on the Federal Budget is likely to be negligible. [email protected] JPMorgan Chase Bank Introducing the Homeland Investment Act Robert Mellman (1-212) 834-5517 Legislation was recently introduced in both the House (H.R.767) and Senate [email protected] (S.596) to temporarily change the tax treatment of US subsidiaries foreign earn- JPMorgan Chase Bank www.morganmarkets.com May 1, 2003 Economic & Policy Research JPMorgan Introducing the Homeland Investment Act JPMorgan Chase Bank, New York Page 2 Anne Swope (1-212) 834-7566 [email protected] ings. These bills, the Homeland Investment Act of 2003 and A stylized example of tax lawproposal Invest in the USA Act of 2003, would temporarily reduce In this example Acme International earns $100 abroad and pays the US tax rate on foreign subsidiary earnings that are dis- $10 in foreign taxes. No. US taxes are paid because the earnings tributed to the United States parent company. Although the are not repatriated. legislation has been proposed separately from the Bush administration's "jobs and growth" stimulus package, it is Under current law, if the profits were repatriated the firm would now being discussed as a possible element of this plan. also owe $35 in US taxes and $4.50 in additional foreign taxes for distributed earnings less a $14.50 tax credit to offset the The current form of the proposed legislation reduces the tax foreign corporate income tax and witholding-tax-paid Thertotal rate to 5.25% on distributions in excess of a corporation's additional tax cost of-repatriating the $90 $25 "normal" annual distribution, and would be effective for distributions made in either 2003 or 2004, depending on Under the proposed law, the US corporate tax would belowered when the legislation becomes law. by 85% from $35 to $5.25; the foreign tax would also be reduced by 85% to $2.18, and Acme would still have to pay the The Senate Bill differs from the House version in requiring $4.50 foreign witholding tax on distributions The tax cost to the US corporations to provide a domestic reinvestment plan. firm of repatriating the $90 in earnings to the United States is This plan requires firms to describe how repatriated income lowered by more than two-thirds, from $25 to $7.57 will be reinvested in the United States. The Senate bill an- ticipates that an electing corporation's reinvestment plan Example would provide for use of the distributed cash as a source for Foreign Taxable Income $100 funding worker hiring and training, infrastructure, research 10% Foreign Corporate Tax $10 and development, capital investments and/or providing fi- Foreign Net Earnings $90 nancial stability (of the corporation) for purposes of job retention or creation. Tax cost of repatriating-foreign earnings If the Homeland Investment Act becomes law on or before Under Current Law September 2, 2003, the temporary reduced tax rate will only US Corporate Tax at 35% $35. apply to qualifying distributions made on or prior to De- Foreign Tax Credit $14.50 cember 31, 2003 for all calendar year taxpayers. This im- Foreign Withholding Tax $4.50 plies that any resulting capital flows would occur in a very Additional Tax Burden $25.00 short period of time. If the Act becomes law after Septem- ber 2, 2003, the reduced tax rate would apply to distribu- Under Proposed Law tions made during 2004 for calendar year taxpayers. US Corporate Tax at 5 25% $5.25 Foreign Tax Credit -$2.18 Motivation for changing the law Foreign Withholding Tax $4.50 Unlike most other industrial countries, current US tax law Additional Tax Burden $7.57 provides multinational firms with strong incentives to keep earnings from foreign operations outside the United States, even when efficiency considerations would argue that the funds be used within the United States. US corporations: profits earned abroad billions of dollars percent Under international tax principles, primary jurisdiction to 210 28 Profits earned abroad tax income is given to the country where the foreign subsid- 180 iaries operate. The accumulated earnings of a US 24 150 corporation's foreign subsidiaries are generally not subject to US corporate income taxation until the earnings are actu- 120 20 ally distributed to the corporate parent as a dividend. As a 90 general principle, US tax on repatriated income is imposed 16 60 Share of total profits to bring the total corporate tax rate to 35%. In countries in V 30 12 which tax rates are below 35%, an additional US tax gener- 85 87 89 91 93 95 97 '99 01 May 1, 2003 Economic & Policy Research PMorgan Introducing the Homeland Investment Act JPMorgan Chase Bank, New York Page 3 Bruce Kasman (1-212) 834-5515 [email protected] ally is paid when earnings are repatriated. Thus, foreign Foreign undistributed earnnings by credit rating investments financed with foreign earnings of US multina- share of tionals typically have been more attractive than returns on undistributed earnings domestic investments financed with foreign earnings (after AAA 22.9 additional taxes are paid to repatriate the earnings). To be AA 9.9 sure, US tax rules are far more complex than this short de- AA- 11.5 scription suggests. Often they operate to create disincen- A+ 13.6 tives to repatriate foreign earnings even when tax rates abroad are high. A 10.3 A- 9.4 In lowering the tax rate to 5.25%, the cost of repatriating BBB+ 3.3 earnings is significantly reduced. Firms can repatriate funds BBB 10.3 at a lower tax rate and may receive a partial tax credit for Lower 8.8 taxes paid abroad. A stylized example presented in the ac- companying box (previous page) makes this point clear. In Foreign undistributed earnings by sector the example, costs of repatriating earnings are cut by more share of than two-thirds. undistributed earnings Manufacturing 39.7 Many firms have large pools of accumulated earnings from High tech and telecom 17.7 foreign operations but lack promising investment opportu- nities for use of the funds abroad. In particular, tax laws Pharmaceuticals and health care 27.0 make it difficult to structure direct investments from one Consumer 12.2 subsidiary to another. And while the US parent can gener- Energy 9.6 ally borrow as an alternative to repatriating funds, the cur- Finance and insurance 6.5 rent environment is one in which firms have strong incen- Other 5.0 tives to deleverage. Risk considerations should also pro- Note: Both tables based on the sample of 237 S&P 500 corporations that report reinvested mote repatriation. Absent a US tax bite, the risk of political foreign earnings. change or shifting foreign tax regimes create disincentives The Joint Committee on Taxation analyzed a proposal simi- for holding assets in many parts of the world. lar to the current one in 2001. It estimated that repatriated earnings would rise by $135 billion in the first year after The primary motivation of the change in the law is to allow legislation is effective. The estimated revenue impact was firms to repatriate these foreign earnings to promote long- modest. A small positive $4.1 billion gain in the first year term growth. The hope is that some of these funds would be was estimated to be temporary. Over ten years the legisla- used in ways that boost US investment and hiring. That a tion was estimated to reduce revenues by a net $3.9 billion. reduction in the tax rate on repatriating earnings might have The Joint Committee has provided little detail in how it ar- little if any net cost to the US Treasury is also appealing. rived at these estimates. There would be a net loss in revenues from firms that planned to repatriate earnings in the future and would now JPMorgan's assessment of the Homeland Investment Act bring these funds home at a lower tax rate. However, firms begins with an estimate of the size of the accumulated for- that keep virtually all their foreign earnings abroad to avoid additional taxes under current law would have incentive to eign subsidiary earnings that would be available for repa- triation to the United States. In the audited financial state- repatriate earnings currently under the proposal. ments of many S&P 500 corporations, the cumulative amounts of foreign subsidiary earnings that are permanently Foreign subsidiary earnings: A large pool exists or indefinitely reinvested outside the US hereafter, rein- Although the motivation of the legislation is clear, there is vested foreign earnings) are disclosed. little information available to assess the likely size of in- flows that will be generated under the new law and its mac- These figures generally appear in the tax footnote to audited roeconomic effects. financial statements. They are available because, under May 1, 2003 Economic & Policy Research JPMorgan Introducing the Homeland Investment Act JPMorgan Chase Bank, New York Page 4 Anne Swope (1-212) 834-7566 [email protected] GAAP, all corporations that consider all or some of their $500 billion in estimated retained foreign earnings foreign subsidiary earnings as permanently or indefinitely reinvested outside the US-and therefore do not accrue a Financial statements show $406 billion in accumulated foreign deferred tax liability-are required to disclose the amount subsidiary earnings for the S&P 500. This figures likely underes- in theiraudited financial statem entsF inancial statements timates the size of the total pool of foreign earnings that could indicate that the reinvested foreign earnings of the S&P 500 potentially be repatriated corporations that could potentially be repatriated following passage of the Homeland Investment Act is $406 billion. The S&P 500 is a subset of the entire corporate sector S&P 500 operating earnings has recently averaged about 60% of Most of these earnings are held by companies with high overall after tax earnings. Its share of foreign earnings is likely credit ratings (see tables, page 3). Based on S&P ratings, larger, although no official breakdown is available. more than three fourths of the earnings are held by compa- nies that are rated A or higher. Sectorally, manufacturing The aggregate reinvested foreign earnings of corporations in and pharmaceutical companies account for the largest con- the S&P 500 includes reinvested foreign earnings of only 237 centration of accumulated foreign earnings, more than one- corporations. The remaining 263 corporations did not overtly half of earnings held abroad. disclose reinvested foreign earnings In some cases, the tax effects but not the total amount of foreign subsidiary earnings There are good reasons to think that this $406 billion figure are disclosed. For our calculation, these companies are treated underestimates the total pool of earnings that would be eli- as if they have no reinvested foreign earnings gible for repatriation (see box, page 4). Indeed, this view is confirmed by an alternative estimate based on IRS data for There are foreign subsidiary earnings that have not been repa- a larger sample of firms. Taken together, the total pool of triated but also not been treated as permanently reinvested. reinvested foreign earnings eligible for repatriation is esti- These earnings could also be repatriated if the bill becomes law. mated at about $500 billion. An alternative exercise employs IRS data for the 7500 largest Survey points to large-scale repatriation controlled foreign corporations for 1998 and points to accumu- lated foreign subsidiary earnings in 2002 of close to $500 billion. The existence of a large pool of reinvested foreign earnings This level appears consistent with a scaled up estimate from the provides little insight as to the likely size of repatriated smaller S&P sample: funds under the tax plan. In order to estimate the likely ef- fect of the legislation, an informal survey of large firms was Survey results, repatriation of reinvested foreign earnings conducted. The survey sampled tax and treasury depart- percent of reinvested foreign earnings ments of 28 firms. Their reinvested foreign earnings repre- sent about one-quarter of the aggregate $406 billion mea- 60 sured in the S&P 500 sample. The results of the survey 50 highlight the following: 40 A strong incentive to repatriate. Respondents representing 30 slightly over half of the sample-both as a share of the 20 number of respondents and as a share of reinvested foreign 10 earnings-indicate that substantially all of their earnings 0 would be repatriated. Most other companies indicated that Substantially all Some None some of their earnings would be repatriated. Only two re- spondents, accounting for about 8.7% of reinvested foreign Estimate of repatriated earnings earnings of the sample, did not plan to repatriate foreign billions of dollars earnings to the United States. From Firms From Firms Repatriating Repatriating Dollars Cash flow and repatriation. Adequate liquidity appears to Substantially All Some Repatriated Share of sample 50.3% 41.2% be an important consideration for firm's willingness to repa- triate. Firms with large cash balances globally appear more Percent repatriated: committed to repatriating all their reinvested foreign earn- Higher estimate 100% 60% $375 Lower estimate 80% 30% $265 1. Corporations may change their reinvestment strategies, however, at which time Note: Estimates are based on a JPMorgan survey of 28 firms accounting for roughly 25% of deferred taxes may be required to be accrued. all accumulated earnings by the S&P 500 sample of very large firms. May 1, 2003 Economic & Policy Research JPMorgan Introducing the Homeland Investment Act JPMorgan Chase Bank, New York Page 5 Bruce Kasman (1-212) 834-5515 [email protected] ings. Corporations that do not have sufficient cash would S&P sample and survey group have to borrow the cash at the foreign subsidiary level, liq- $ billion uidate operating assets, or distribute property, all of which Global Lesser of Reinvested have collateral consequences and make the decision signifi- Group Reinvested Foreign Cash & Cash Foreign Earnings or cantly more complex. Liquidity is also significant as there Earnings Equivalents Global Cash and Equiv. would be cash taxes due on the distributed earnings. In ad- dition to US taxes, most countries impose a withholding tax when earnings are distributed. S&P 500 sample 407 374 193 Survey Group 102 76 59 The results of the survey point to a substantial flow of repa- Note: The S&P sample represents the 237 corporations in the S&P 500 that triated foreign earnings (see table, page 4). The estimates disclose reinvested foreign earnings. The survey group represents the 28 corporations sampled by JPMorgan. The amount of global cash and range from $265- $375 billion. cash equivalents for each company is the amount reflected on each company's audited financial statements. The aggregation of corpora- The possibility that the survey sample is biased towards tions using the lesser of their reported reinvested foreign earnings or global cash is reported in the last column. companies with high levels of liquidity-and therefore a greater proclivity to repatriate earnings-was also examined (see top table, page 5). In the aggregate, companies in the survey sample do not appear to have a larger cash position relative to those in the broader S&P 500 sample. This find- Survey results: uses of repatriated funds ing holds when the data are aggregated such that repatri- survey of 28 firms; respondents could mention more than one use ated flows are no larger than a corporation's available cash Percent of position. Number respondents Pay down outstanding debt 13 46 In all, $300 billion looks to be a reasonably conservative Finance capital spending 11 39 estimate of the magnitude of foreign earnings that could be Fund R&D, venture capital, or acquisitions 11 39 repatriated under the proposed legislation. This estimate is Buy back stock 5 18 more than twice as large as that produced by the Joint Com- Use cash for working capital 3 11 mittee on Taxation. Might pay dividend (if double taxation ends) 3 11 Fund underfunded pension fund 1 4 A modest boost to growth and deleveraging The ultimate intent of the Homeland Investment Act is to provide a boost to US macroeconomic performance. In con- sidering the possible benefits of repatriating $300 billion in foreign earnings, once again the survey provides guidance cash or is used for stock buy-banks and shoring up pension (bottom table, page 5). Most corporations point to shoring funds. up corporate finances-buying back debt, increasing levels of liquid assets, rebuilding pension funds or even retiring Under these assumptions, $150 billion of corporate debt equity-as a key priority for the use of these funds. How- would be paid down, equivalent to about 3% of total nonfi- ever, a substantial number of corporations also indicate that nancial corporate debt. For many firms repatriating funds, a portion of the funds will be used to finance activity: capi- the percentage reduction in debt would be much greater. tal spending, research and development, and the like. The share allocated to new expenditures amounts to about There are no hard numbers on how the money would be al- $50 billion per year in new spending. At this magnitude, located among these varied purposes. As a rough translation GDP would likely be boosted by about one half a percent- of the survey results, assume that 50% of the $300 billion is age point. The biggest benefits would likely come in spend- used for debt repayment and 35% is used for spending - on ing on equipment and software and new plant. The boost to research and development or capital expenditure - spread the total national level of capital spending would be 2-3% out over a two-year period. The remaining 15% remains in in each of the two years. May 1, 2003 Economic & Policy Research JPMorgan Introducing the Homeland Investment Act JPMorgan Chase Bank, New York Page 6 Anne Swope (1-212) 834-7566 [email protected] Budget impact is expected to be small tial offset to the $10 billion to $15 billion gain. Most likely, the past trend of earnings accumulating abroad would con- The effects of the proposed change in the tax law on the tinue to prevail, and this partial offset would be minimal. federal budget are likely to be relatively modest: positive in the short run and slightly positive in the longer run as well. Based on the estimate of the repatriated earnings, cash tax Close to $100 billion shift to dollar assets payments of roughly $10 billion to $15 billion as a direct Regarding the currency impact of the tax change, the key result of the legislation would accrue to the Treasury in the issue is the extent of the shift from nondollar to dollar assets first year. This assumes an effective tax rate of 3.5-5%, after that takes place. Anecdotal evidence gained from talking to adjusting for foreign tax credits. US corporations suggest that a large portion of foreign earnings held abroad are held in US dollars. Although no To the extent that some of the reinvested foreign earnings hard information is available, a reasonable estimate places would have been distributed in the foreseeable future and the dollar share of reinvested foreign earnings at between taxed at the statutory rate of 35% absent the proposed legis- one-half and three-quarters. As a result, the repatriation of lation, the present value of the foregone taxes on these earn- $300 billion in foreign earnings is likely to produce a one- ings (difference between 35% and 5.25%) would be a par- time currency shift of around $100 billion. Copyright 2003 J.P. Morgan Chase & Co. All rights reserved. PMorgan is the marketing name for J.P. Morgan Chase & Co., and its subsidiaries and affiliates worldwide. J.P. Morgan Securities Inc. is a member of NYSE and SIPC. JPMorgan Chase Bank is authorised by the FSA and a member of FDIC. J.P. Morgan Futures Inc. is a member of the NFA. J.P. Morgan Securities Ltd. and J.P. Morgan plc are authorised by the FSA and members of the LSE. J.P. Morgan Europe Limited is authorized by the FSA. J.P. Morgan Equities Limited is a member of the Johannesburg Securities Exchange and is regulated by the FSB. J.P. Morgan Securities (Asia Pacific) Limited is registered as an investment adviser with the Securities & Futures Commission in Hong Kong and its CE number is AAJ321. J.P. Morgan Securities Singapore Private Limited is a member of Singapore Exchange Securities Trading Limited and is regulated by the Monetary Authority of Singapore ("MAS"). J.P. Morgan Securities Asia Private Limited is regulated by the MAS and the Financial Services Agency in Japan. J.P. Morgan Australia Limited (ABN 888 is a licensed securities dealer. Additional information is available upon request. Information herein is believed to be reliable but JPMorgan does not warrant its completeness or accuracy. Opinions and estimates constitute our judgment and are subject to change without notice. Past performance is not indicative of future results. The investments and strategies discussed here may not be suitable for all investors; if you have any doubts you should consult your investment advisor. The investments discussed may fluctuate in price or value. Changes in rates of exchange may have an adverse effect on the value of investments. This material is not intended as an offer or solicitation for the purchase or sale of any financial instrument. PMorgan and/or its a ffiliates and employees may hold; position, may underta or have already undertaken an own account transaction or act as market maker in the financial instruments of any issuer discussed herein or any related financial instruments, or act as underwriter, placement agent, advisor or lender to such issuer. Clients should contact analysts at and execute transactions through a Morgan entity in their home jurisdiction unless governing law permits otherwise. This report should not be distributed to others or replicated in any form without prior consent of JP Morgan. This report has been issued in the U.K. only to persons of a kind described in Article 19 (5), 38, 47 and 49 of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2001 (all such persons being referred to as "relevant persons"). This document must not be acted on or relied on by persons who are not relevant persons. Any investment or investment activity to which this document relates is only available to relevant persons and will be engaged in only with relevant persons. In other European Economic Area countries, the report has been issued to persons regarded as professional investors (or equivalent) in their home jurisdiction.