8-KExhibits & Filings

JPMORGAN CHASE & CO 8-K Report, Exhibit Filing (Oct 2, 2006)

Filed October 2, 2006For Securities:JPMJPM-PCJPM-PDJPM-PKJPM-PLJPM-PMJPM-PJAMJBVYLD

Summary

This 8-K filing from JPMorgan Chase & Co. (JPM) dated October 2, 2006, primarily serves to disclose the filing of two tax opinions from Davis Polk & Wardwell. These opinions relate to specific "Buffered Return Enhanced Notes" that are linked to a weighted basket of international stock indices. The notes have maturity dates of October 1, 2009, and September 30, 2011, respectively. For investors, this filing indicates that JPM has completed the necessary legal and tax reviews for these particular structured products. The inclusion of tax opinions from a reputable firm like Davis Polk & Wardwell suggests a degree of assurance regarding the tax treatment of these notes for potential investors, which is a crucial consideration for structured financial products. Investors interested in these specific notes should review the full tax opinions for details on the tax implications.

Key Highlights

  • 1Filing of two tax opinions from Davis Polk & Wardwell.
  • 2Opinions pertain to "Buffered Return Enhanced Notes".
  • 3Notes are linked to a weighted basket of major international stock indices: Nikkei 225, Dow Jones EURO STOXX 50®, FTSE™ 100, S&P BRIC 40, and CECEEUR.
  • 4Two separate note series are covered, with maturity dates of October 1, 2009, and September 30, 2011.
  • 5These exhibits are incorporated by reference into JPM's Form S-3ASR registration statement.
  • 6The filing is primarily administrative, confirming legal and tax due diligence for these specific debt instruments.

Frequently Asked Questions

The primary purpose of this 8-K filing is to publicly disclose the submission of two tax opinions from the law firm Davis Polk & Wardwell. These opinions concern specific "Buffered Return Enhanced Notes" issued by JPMorgan Chase & Co.

The tax opinions are related to "Buffered Return Enhanced Notes" which are structured financial products. These notes are linked to the performance of a basket of several international stock market indices.

The notes are linked to a weighted basket consisting of the Nikkei 225 Index, the Dow Jones EURO STOXX 50® Index, the FTSE™ 100 Index, the S&P BRIC 40 Index, and the CECEEUR Index.

There are two series of notes mentioned. One series matures on October 1, 2009, and the other matures on September 30, 2011. The tax opinions cover both of these maturity dates.