•  a trader in securities if you elect to use a mark-to-market method of accounting for your securities  holdings;  • a financial institution or an insurance company;  •  a regulated investment company;  • a real estate investment trust;  •  a tax-exempt organization;  • a person liable for alternative minimum tax;  •  a person holding shares or ADSs as part of a hedging, integrated or conversion transaction,  constructive sale or straddle;  •  a person owning, actually or constructively, 10% or more of our voting stock;  • a partnership or other pass-through entity for U.S. federal income tax purposes; or  • a person whose “functional currency” is not the U.S. dollar.  We cannot assure you that a later change in law will not alter significantly the tax considerations that we  describe in this summary.  If a partnership holds our shares or ADSs, the tax treatment of a partner will generally depend upon the  status of the partner and the activities of the partnership. If you are a partner of a partnership holding our shares  or ADSs, you should consult your tax advisor.  You should consult your own tax advisor concerning the particular U.S. federal income tax  consequences to you of the ownership and disposition of the shares or ADSs, as well as the consequences to  you arising under the laws of any other taxing jurisdiction.  In general, for U.S. federal income tax purposes, a U.S. holder who is the beneficial owner of an ADS  will be treated as the owner of the shares underlying such ADS. Deposits or withdrawals of shares, actually or  constructively, by U.S. holders for ADSs will not be subject to U.S. federal income tax.  The U.S. Treasury has expressed concerns that intermediaries in the chain of ownership between the  holder of an ADS and the issuer of the security underlying the ADS may be taking actions that are inconsistent  with the claiming of foreign tax credits by U.S. holders of ADSs. Such actions would also be inconsistent with  the claiming of the reduced rate of tax, described in “—Taxation of Dividends” below, applicable to dividends  received by certain non-corporate holders. Accordingly, the analysis of the credibility of Republic of China  taxes and the availability of the reduced tax rate for dividends received by certain non-corporate holders, each  described in “—Taxation of Dividends” below, could be affected by actions taken by intermediaries in the chain  of ownership between the holder of the ADS and the issuer of the security underlying the ADS.  The gross amount of distributions (other than certain pro rata distributions of shares to all stockholders) you  receive on your shares or ADSs, including net amounts withheld in respect of Republic of China withholding  taxes, will generally be treated as dividend income to you to the extent the distributions are made from our  current and accumulated earnings and profits as calculated according to U.S. federal income tax principles. These  amounts (including withheld taxes) will be includible in your gross income as ordinary income on the day you  actually or constructively receive the distributions, which in the case of an ADS will be the date received by the  depositary. You will not be entitled to claim a dividends-received deduction allowed to corporations under the  Code with respect to distributions you receive from us.  115 Taxation of Dividends  PART I