Reportable Transaction Disclosure Statement

Use Form 8886 to disclose information for each reportable transaction in which you participated. Form 8886 must be filed for each tax year that your federal income tax liability is affected by your participation in the transaction. You may have to pay a penalty if you are required to file Form 8886 but do not do so. You may also have to pay interest and penalties on any reportable transaction understatements. The following are reportable transactions.

• Any listed transaction that is the same as or substantially similar to tax avoidance transactions identified by the IRS.

• Any transaction offered to you or a related party under conditions of confidentiality for which you paid an advisor a fee of at least $50,000 for individuals or $250,000 for partnerships and trusts. See the Instructions for Form 8886.

• Certain transactions for which you or a related party have contractual protection against disallowance of the tax benefits.

• Certain transactions resulting in a loss of at least $2 million in any single tax year or $4 million in any combination of tax years (at least $50,000 for a single tax year if the loss arose from a foreign currency transaction defined in section 988(c)(1), whether or not the loss flows through from an S corporation or partnership).

• Certain transactions of interest entered into that are the same as or substantially similar to transactions that the IRS has identified by notice, regulation, or other form of published guidance as transactions of interest.

See the Instructions for Form 8886 for more details.