P AR T I will be the date received by the depositary, regardless of whether the NT dollars are actually converted into U.S. dollars. If the NT  dollars received as a dividend are not converted into U.S. dollars on the date of receipt, you will have a basis in the NT dollars equal  to their U.S. dollar value on the date of receipt. Any gain or loss you realize if you subsequently sell or otherwise dispose of the NT  dollars will be ordinary income or loss from sources within the United States for foreign tax credit limitation purposes.  Subject to certain conditions and limitations under the Code, you may be entitled to a credit or deduction against your U.S.  federal income taxes for the net amount of any Republic of China taxes that are withheld from dividend distributions made to you.  In determining the amounts withheld in respect of Republic of China taxes, any reduction of the amount withheld on account of a  Republic of China credit in respect of the 10% retained earnings tax imposed on us is not considered a withholding tax and will not  be treated as distributed to you or creditable by you against your U.S. federal income tax. The limitation on foreign taxes eligible for  credit is calculated separately with respect to specific classes of income. For purposes of calculating the foreign tax credit, dividends  we pay with respect to shares or ADSs will generally be considered passive category income from sources outside the United States.  Further, a U.S. holder that  may not be allowed a foreign tax credit for foreign taxes imposed on dividends paid on shares or ADSs. The rules governing  the foreign tax credit are complex. We therefore urge you to consult your tax advisor regarding the availability of the foreign tax  credit under your particular circumstances.  To the extent that the amount of any distribution you receive exceeds our current and accumulated earnings and profits for  a taxable year, as determined under U.S. federal income tax principles, the distribution will first be treated as a tax-free return of  capital, causing a reduction in your adjusted basis in the shares or ADSs and thereby increasing the amount of gain, or decreasing  the amount of loss, you will recognize on a subsequent disposition of the shares or ADSs. The balance in excess of adjusted basis, if  any, will be taxable to you as capital gain recognized on a sale or exchange. However, we do not expect to keep earnings and profits  in accordance with U.S. federal income tax principles. Therefore, you should expect that a distribution will generally be treated as a  dividend.  It is possible that pro rata distributions of shares or ADSs to all stockholders may be made in a manner that is not subject to  U.S. federal income tax. The basis of any new shares or ADSs so received will generally be determined by allocating your basis in  the old shares or ADSs between the old shares or ADSs and the new shares or ADSs, based on their relative fair market values on the  date of distribution.  For U.S. tax purposes, any such tax-free share distribution would not result in foreign source income to you. Consequently,  you may not be able to use the foreign tax credit associated with any Republic of China withholding tax imposed on such distributions  unless you can use the credit (subject to applicable limitations) against U.S. federal income tax due on other foreign source income in  the appropriate category for foreign tax credit purposes.  When you sell or otherwise dispose of your shares or ADSs, you will generally recognize capital gain or loss in an amount  equal to the difference between the U.S. dollar value of the amount realized for the shares or ADSs and your basis in the shares or  ADSs, determined in U.S. dollars. For foreign tax credit limitation purposes, such gain or loss will generally be treated as U.S. source  gain or loss. If you are an individual and have held the shares or ADSs being sold or otherwise disposed for more than one year, your  gain recognized will be eligible for reduced rates of taxation. Your ability to deduct capital losses is subject to limitations.  Any Republic of China securities transaction taxes that you pay generally will not be creditable foreign taxes for U.S. federal  income tax purposes, but you may be able to deduct such taxes, subject to certain limitations under the Code. You are urged to consult  your tax advisors regarding the U.S. federal income tax consequences of these taxes.  119 Taxation of Capital Gains ●  has held shares or ADSs for less than a specified minimum period during which it is not protected from risk of loss, or  ●  is obligated to make payments related to the dividends, 