J.P.Morgan
JPMorgan Alerian MLP Index ETNs (AMJ)
Frequently Asked Questions About Tax Treatment
--------------------------------------------------------------------------------
The JPMorgan Alerian MLP Index Exchange Traded Notes ("ETNs") are senior,
unsecured obligations of JPMorgan Chase & Co. (the "Issuer") that provide
investors synthetic exposure to the Alerian MLP Index (the "Index"). The ETNs
pay variable quarterly coupons1 determined by reference to the cash
distributions paid on the MLPs in the Index, less accrued tracking fees.2
Investors can trade the ETNs on the NYSE Arca Inc. or receive a cash payment at
the scheduled maturity or upon early repurchase,3 based on the performance of
the Index.
You should review carefully the section entitled "Selected Purchase
Considerations - Tax Treatment" in the relevant pricing supplement, as well as
the section entitled "Certain U.S. Federal Income Tax Consequences" in the
accompanying product supplement. This document does not address all aspects of
the U.S. federal income taxation of the ETNs that may be relevant to you in
light of your particular circumstances or if you are a holder of ETNs who is
subject to special treatment under the U.S. federal income tax laws. You should
consult your tax adviser regarding the U.S. federal income tax consequences of
an investment in the ETNs.
What is the tax treatment of the ETNs?
As more fully described in the relevant pricing supplement and product
supplement, we believe it is reasonable to treat the ETNs as "open transactions"
for U.S. federal income tax purposes.
Will investors in the ETNs receive Schedule K-1s?
No. Investors in the ETNs will not receive a Schedule K-1 by virtue of their
investment in the ETNs.
What is the tax treatment of the coupons for U.S. holders?
As more fully described in the relevant pricing supplement and product
supplement, the Issuer and investors in the ETNs agree to treat the coupons as
ordinary income at the time accrued or received, in accordance with the
investor's method of accounting for U.S. federal income tax purposes. It is
expected that a broker or custodian (or entity through which an investor holds
his or her interest in the ETNs) will report the coupons paid on the ETNs as
ordinary income on Form 1099-MISC.
Why does the tax treatment of the coupons paid on the ETNs differ from the tax
treatment of the cash distributions made by MLPs? Investors in the ETNs do not
hold direct interests in the MLPs underlying the Index. Investors in the ETNs
hold senior, unsecured obligations of J.P. Morgan Chase & Co. that provide
synthetic exposure to the Alerian MLP Index.
What is the tax treatment upon sale, exchange or redemption of the ETNs for U.S.
holders?
As more fully described in the relevant pricing supplement and product
supplement, assuming the ETNs are treated for U.S. federal income tax purposes
as "open transactions" with respect to the Index and not as debt instruments,
upon a sale or exchange (including early repurchase or redemption at maturity)
of the ETNs, if you are a U.S. holder (as defined in the product supplement),
you should recognize gain or loss equal to the difference between the amount
realized on the sale or exchange and your tax basis in the ETNs, which should
equal the amount you paid to acquire the ETNs. This gain or loss should be
capital gain or loss, subject to the discussion of the "constructive ownership"
rules provided in the relevant pricing supplement and product supplement, and
should be long-term capital gain or loss if you have held the ETNs for more than
a year.
1. The quarterly coupons, which are referred to as Coupon Amounts in the
relevant pricing supplement, are determined by reference to the cash
distributions, if any, paid on the MLPs underlying the Index, less an Accrued
Tracking Fee as more fully described in the relevant pricing supplement and
product supplement.
2. The "Accrued Tracking Fee" for a given coupon period, as more fully described
in the relevant pricing supplement, represents an amount equal to the Tracking
Fee of 0.85% per annum accrued for that coupon period multiplied by the Current
Indicative Value on the Index Business Day prior to the date of determination,
plus the aggregate amounts, if any, by which the previous Accrued Tracking Fees
have exceeded the cash distributions, if any, made by the underlying MLPs. 3.
Investors may request on a weekly basis that the Issuer repurchase a minimum of
50,000 notes prior to the maturity date, subject to the procedures described in
the relevant pricing supplement. Early repurchases will be subject to a
Repurchase Fee of 0.125%, as further described in the relevant pricing
supplement and product supplement.
March 8, 2010
|
|
|