8.1 | Tax Opinion of Davis Polk & Wardwell relating to Principal Protected Notes Linked to an Equally Weighted Basket Consisting of the Dow Jones EURO STOXX 50® Index, the Nikkei 225 Index and the S&P 500® Index due May 31, 2013 |
8.2 | Tax Opinion of Davis Polk & Wardwell relating to Principal Protected Notes Linked to an Equally Weighted Basket Consisting of the Dow Jones EURO STOXX 50® Index, the Nikkei 225 Index and the S&P 500® Index due November 30, 2012 |
8.3 | Tax Opinion of Davis Polk & Wardwell relating to Index Basket Knock-Out Notes Linked to an Equally Weighted Basket Consisting of the S&P 500® Index, the Nikkei 225 Index and the Dow Jones EURO STOXX 50® Index due November 30, 2010 |
8.4 | Tax Opinion of Davis Polk & Wardwell relating to Index Basket Knock-Out Notes Linked to an Equally Weighted Basket Consisting of the S&P 500® Index, the Nikkei 225 Index and the Dow Jones EURO STOXX 50® Index due November 30, 2010 |
8.5 | Tax Opinion of Davis Polk & Wardwell relating to Contingent Interest Index Basket Knock-Out Notes Linked to an Equally Weighted Basket Consisting of the S&P 500® Index, the Nikkei 225 Index and the Dow Jones EURO STOXX 50® Index due November 30, 2010 |
8.6 | Tax Opinion of Davis Polk & Wardwell relating to Reverse Exchangeable Notes due February 29, 2008 Each Linked to the Common Stock of a Different Single Reference Stock Issuer |
8.7 | Tax Opinion of Davis Polk & Wardwell relating to Reverse Exchangeable Notes due February 29, 2008 Each Linked to the Common Stock of a Different Single Reference Stock Issuer |
8.8 | Tax Opinion of Davis Polk & Wardwell relating to Reverse Exchangeable Notes due May 30, 2008 Each Linked to the Common Stock of a Different Single Reference Stock Issuer |
8.9 | Tax Opinion of Davis Polk & Wardwell relating to Reverse Exchangeable Notes due May 30, 2008 Each Linked to the Common Stock of a Different Single Reference Stock Issuer |
8.10 | Tax Opinion of Davis Polk & Wardwell relating to Reverse Exchangeable Notes due November 28, 2008 Each Linked to the Common Stock of a Different Single Reference Stock Issuer |
8.11 | Tax Opinion of Davis Polk & Wardwell relating to Reverse Exchangeable Notes due November 28, 2008 Each Linked to the Common Stock of a Different Single Reference Stock Issuer |
8.12 | Tax Opinion of Davis Polk & Wardwell relating to Knock-Out Return Enhanced Notes Linked to the MSCI EAFE® Index due January 2, 2009 |
8.13 | Tax Opinion of Davis Polk & Wardwell relating to Return Enhanced Notes Linked to the NASDAQ-100 Index® due January 2, 2009 |
8.14 | Tax Opinion of Davis Polk & Wardwell relating to Reverse Exchangeable Notes due May 30, 2008 Each Linked to the Common Stock of a Different Single Reference Stock Issuer |
8.15 | Tax Opinion of Davis Polk & Wardwell relating to Principal Protected Notes Linked to a Weighted Basket Consisting of the S&P 500® Index, the MSCI EAFE® Index and the iShares® MSCI Emerging Markets Index Fund due November 30, 2012 |
8.16 | Tax Opinion of Davis Polk & Wardwell relating to 4.00% (equivalent to 16.00% per annum) Reverse Exchangeable Notes due March 4, 2008 Linked to the Common Stock of Merrill Lynch & Co., Inc |