To ensure compliance with requirements imposed by the United States Treasury Department, you are hereby informed that any advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. This advice may not be forwarded without our express written consent.

This prominent disclaimer will not appear, however, if the written tax advice is in the form of, and meets the requirements of, a “covered opinion” (a term defined in the Circular 230 regulations). Generally, a “covered opinion” issued by us will include written opinions we provide to clients who have retained Santos Associates Accountants to advise them on federal tax consequences of specific transactions.