8-KExhibits & Filings

JPMORGAN CHASE & CO 8-K Report, Exhibit Filing (Jun 13, 2006)

Filed June 13, 2006For Securities:JPMJPM-PCJPM-PDJPM-PKJPM-PLJPM-PMJPM-PJAMJBVYLD

Summary

JPMorgan Chase & Co. (JPM) filed a Form 8-K on June 12, 2006, reporting event details from June 8, 2006. This filing primarily serves to attach several tax opinions from the law firm Davis Polk & Wardwell. These opinions relate to various structured note offerings, including "Buffered Return Enhanced Notes" linked to the Nikkei 225 Index, S&P 500 Index, and Dow Jones EURO STOXX 50 Index, as well as "Semi Annual Review Notes" linked to the S&P 500 Index. For investors, the significance of this filing lies in the confirmation of tax advice sought for these specific debt instruments. The presence of tax opinions from a reputable firm like Davis Polk & Wardwell indicates that JPMorgan Chase is providing its clients with detailed tax guidance concerning the potential tax implications of investing in these notes. Investors considering these products should review the underlying offering documents and understand that these tax opinions are specific to the noted series of notes and do not constitute a guarantee of tax treatment.

Key Highlights

  • 1JPM filed an 8-K on June 12, 2006, pertaining to events on June 8, 2006.
  • 2The filing includes tax opinions from Davis Polk & Wardwell.
  • 3The tax opinions are related to specific structured note offerings by JPMorgan Chase.
  • 4One offering is 'Buffered Return Enhanced Notes' linked to the Nikkei 225 Index (due June 20, 2007).
  • 5Another offering is 'Buffered Return Enhanced Notes' linked to the S&P 500® Index (due October 18, 2007).
  • 6A 'Semi Annual Review Notes' linked to the S&P 500® Index (due June 23, 2009) is also covered.
  • 7A further offering is 'Buffered Return Enhanced Notes' linked to the Dow Jones EURO STOXX 50® Index (due June 20, 2007).

Frequently Asked Questions

The primary purpose of this Form 8-K filing is to publicly disclose tax opinions provided by Davis Polk & Wardwell concerning several specific structured note offerings issued by JPMorgan Chase & Co.

The tax opinions are related to structured notes, specifically 'Buffered Return Enhanced Notes' linked to major indices like the Nikkei 225, S&P 500, and Dow Jones EURO STOXX 50, as well as 'Semi Annual Review Notes' linked to the S&P 500.

No, these are legal opinions on potential tax consequences. They are based on specific information and legal interpretations and do not guarantee how tax authorities or courts will treat the investments. Investors should consult their own tax advisors.

The inclusion of tax opinions from a reputable law firm like Davis Polk & Wardwell suggests that JPMorgan Chase is providing formal guidance on the tax implications of these specific structured note products. It indicates diligence in advising clients but does not guarantee outcomes.