Global Trustee and Fiduciary Services News and Views Issue 48

All views, opinions and estimates expressed in this communication (the “Communication”) (i) may change without notice, and

(ii) may differ from those views, opinions and estimates held or expressed by Citigroup Inc., its subsidiaries and branches thereof

worldwide (together “Citi”) or other Citi personnel.

This Communication is provided for information and discussion purposes only. Unless otherwise expressly indicated, this

Communication does not constitute an offer or recommendation to purchase or sell any financial instruments or other products

and does not take into account the investment objectives or financial situation of any particular person. Recipients of this

Communication should obtain advice based on their own individual circumstances from their own tax, financial, legal and other

advisors before making an investment decision or taking any other action and only make such decisions on the basis of the

recipient’s own objectives, experience and resources and on the basis of the recipient’s own tax, financial and legal advice. The

information contained in this Communication is based on generally available information and, although obtained from sources

believed by Citi to be reliable, its accuracy and completeness cannot be assured, and such information may be incomplete or

condensed. It has not been prepared by research analysts, and the information in this communication is not intended to constitute

“research” as that term is defined by applicable regulations. Furthermore, the information in it is general, may not reflect recent

developments and was not intended and must not be considered or relied on as legal, tax, financial or any other form of advice.

Please contact your legal counsel and other advisors if you have any questions or concerns about the matters addressed here.

You and your legal counsel are encouraged to actively review and monitor regulations applicable to you. No liability is accepted by

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from this Communication. Such exclusion does not operate to exclude or restrict Citi’s liability for fraud or other liabilities which

cannot be excluded or restricted by law.

IRS Circular 230 Disclosure: Citi, its employees and its affiliates are not in the business of providing, and do not provide, tax or

legal advice to any taxpayer outside of Citi. Any statements in this Communication to tax matters were not intended or written to

be used, and cannot be used or relied upon, by any taxpayer for the purpose of avoiding tax penalties. Any such taxpayer should

seek advice based on the taxpayer’s particular circumstances from an independent tax advisor.

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Citi accepts no liability whatsoever for the actions of third parties in this respect.

trademarks and service marks of Citigroup Inc. and/or its affiliates and are used and registered throughout the world.

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