IRS CIRCULAR 230 NOTICE: In order to ensure compliance with IRS Circular 230, we must inform you that any U.S. tax advice contained in this transmission and any attachments hereto is not intended or written to be used by any person for the purpose of (i) avoiding any penalty that may be imposed by the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any tax-related matter(s) addressed herein. (The foregoing disclosure has been affixed pursuant to U.S. Treasury Regulations governing tax practice.)