343 Value added tax Other taxes and duties II Taxation in the United States In general, no value added tax will arise in respect of payments in consideration for the issue of Aegon common shares or in respect of  a cash payment made under Aegon common shares, or in respect of a transfer of Aegon common shares. No registration tax, customs duty, transfer tax, stamp duty, capital tax or any other similar documentary tax or duty will be payable in  the Netherlands by a holder of Aegon common shares in respect of or in connection with the subscription, issue, placement, allotment,  delivery or transfer of the Aegon common shares. This section describes certain US Federal income tax consequences to beneficial holders of common shares that are held as capital  assets. This section does not address all US Federal income tax matters that may be relevant to a particular holder. Each investor  should consult their tax advisor with respect to the tax consequences of an investment in the common shares. This section does not  address tax considerations for holders of common shares subject to special tax rules including, without limitation, the following: Further, this section does not address alternative minimum tax consequences or the indirect effects on the holders of equity interests  in a holder of common shares. This section also does not describe any tax consequences arising under the laws of any taxing jurisdiction  other than the Federal income tax laws of the US Federal government. This section is based on the US Internal Revenue Code of 1986, as amended, US Treasury regulations and judicial and administrative  interpretations, in each case as in effect and available on the date of this Annual Report. All of the foregoing is subject to change,  which change could apply retroactively and could affect the tax consequences described below. For the purposes of this section, a “US holder” is a beneficial owner of common shares that is, for US Federal income tax purposes: A non-US holder is a beneficial owner of common shares that is not a US holder. The gross amount of any distribution (including any amounts withheld in respect of Dutch withholding tax) actually or constructively  received by a US holder with respect to common shares will be taxable to the US holder as a dividend to the extent of Aegon’s current  and accumulated earnings and profits as determined under US Federal income tax principles. Such dividends will not qualify for the  dividends received deduction otherwise allowable to corporations. Distributions in excess of current and accumulated earnings and  profits are treated under US tax law as non-taxable return of capital to the extent of the US holder’s adjusted tax basis in the common  shares. Distributions in excess of earnings and profits and such adjusted tax basis will generally be taxable to the US holder as capital  gain from the sale or exchange of property. However, Aegon does not maintain calculations of its earnings and profits under US Federal  income tax principles. Therefore, US holders of Aegon shares will generally be taxed on all distributions as dividends, even if some  portion of the distributions might otherwise be treated as a non-taxable return of capital or as capital gain if the amount of  ■ Financial institutions; ■ Insurance companies; ■ Dealers or traders in securities or currencies; ■ Tax-exempt entities; ■ Regulated investment companies; ■ Persons that will hold the common shares as part of a “hedging” or “conversion” transaction or as a position in a “straddle” or as  part of a “synthetic security” or other integrated transaction for US Federal income tax purposes;  ■ Holders that own (or are deemed to own for US Federal income tax purposes) 10% or more of the voting shares of Aegon;  ■ Partnerships or pass-through entities or persons who hold common shares through partnerships or other pass-through entities; and  ■ Holders that have a “functional currency” other than the US dollar.  ■ a citizen or individual resident of the United States; ■ a corporation created or organized in or under the laws of the United States or any state of the United States (including the District  of Columbia); ■ an estate, the income of which is subject to US Federal income taxation regardless of its source; or ■ a trust, if a court within the United States is able to exercise primary supervision over its administration and one or more US persons  have the authority to control all of the substantial decisions of such trust. Tax consequences to US Holders Distributions