FWP 1 dfwp.htm FREE WRITING PROSPECTUS IPATH TAX FAQS Free Writing Prospectus iPath Tax FAQs

Free Writing Prospectus

Filed Pursuant to Rule 433

Registration No. 333-169119

July 5, 2011

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U.S. FEDERAL INCOME TAX CONSIDERATIONS

iPath® Exchange Traded Notes

iPath Exchange Traded Notes (ETNs) provide investors with cost-effective exposure to asset classes that have not always been easy to access. Here are answers to questions financial professionals and individuals commonly ask about the tax treatment of the iPath ETNs currently available.

How are iPath ETNs treated for U.S. federal income tax purposes

Barclays and investors agree to treat all iPath ETNs, except single currency ETNs, for all U.S. federal income tax purposes, as prepaid executory contracts with respect to the relevant index. If such iPath ETNs are so treated, investors should recognize gain or loss upon the sale, redemption or maturity of their iPath ETNs as the amount equal to the difference between the amount they receive at such time and their tax basis in the securities. Investors generally agree to treat such gain or loss as capital gain or loss, except with respect to iPath currency ETNs, for which investors agree to treat such gain or loss as ordinary, as detailed in the chart below.

The following table summarizes certain U.S. federal tax consequences that holders of iPath ETNs and Barclays agree to be subject to by purchasing an iPath ETN. These tax consequences, however, are not certain and alternative treatments are possible. Please see the applicable prospectus for a more complete discussion of the primary tax treatment and alternative tax characterizations that are possible with respect to each iPath ETN.

TREATMENT RECOGNITION OF

TYPE AT MATURITY CURRENT INCOME

Alternatives Capital Gains No

Buy-Write Capital Gains No

Commodities Capital Gains No

Equity Capital Gains No

Fixed Income Capital Gains No

Leveraged Capital Gains No

Currency

Carry Trade Ordinary Income No

Single Currency Ordinary Income Yes

What makes iPath ETNs an attractive investment option

Unlike mutual funds that may be required to make taxable distributions to shareholders, the iPath ETNs currently available will not make taxable distributions. Therefore, holders of iPath ETNs (other than the single currency ETNs) should, assuming they are treated as described earlier, generally not be required to include amounts in income prior to sale, redemption or maturity. This enables investors to control the timing of taxable events related to their investment in iPath ETNs. However, the IRS and U.S. Treasury are actively considering the tax treatment of instruments such as iPath ETNs, which could change.

Is there an IRS or court ruling that governs the U.S. tax treatment of iPath ETNs

Yes, for iPath single currency ETNs only.

What is the ruling on the U.S. tax treatment of iPath single currency ETNs

Revenue ruling 2008-1, issued on December 7, 2007, holds that certain financial instruments linked directly to the value of a foreign currency—regardless of whether the instrument is privately offered, publicly offered or traded on an exchange—should be treated like debt for federal tax purposes. Revenue Ruling 2008-1 extends to iPath single currency ETNs.

What is Barclays’ reaction to the ruling on the U.S. tax treatment of iPath single currency ETNs

The ruling provides investors clarity on the tax treatment of certain financial instruments linked directly to the value of a foreign currency—regardless of whether the instrument is privately offered, publicly offered or traded on an exchange.

What does it mean for iPath single currency ETN investors

This means that any interest accrued (net of fees) during the life of the note is taxable to investors, even though the interest is reinvested and not paid out until the holder sells the ETN or the

This information should not be considered tax advice. Investors are urged to consult their tax advisor with regard to their specific situation.


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iPATH FEDERAL INCOME TAX CONSIDERATIONS

note matures. It also means that a gain or loss from the sale or redemption of the notes will be ordinary and investors will not be able to elect capital gains treatment.

Do iPath single currency ETN investors need to submit a form to the IRS requesting a certain tax treatment

No, it is not necessary to elect any specific treatment since the IRS has ruled how financial instruments linked directly to the value of a foreign currency should be treated from a tax perspective. Most custodians will provide Form 1099 OID for annual tax reporting purposes.

What are the benefits of investing in iPath single currency ETNs

Institutional and individual investors increasingly recognize that currency exposure may constitute a separate asset class to provide portfolio diversification and add potential portfolio returns. The iPath single currency ETNs provide simple, transparent and cost-effective access to three significant exchange rates. In addition, because they make no distributions, holders benefit from daily compounding.

What is the current tax status of equity, fixed income, leveraged, commodity and certain alternatives ETNs

The revenue ruling does not apply to iPath ETNs other than iPath single currency ETNs. On December 7, 2007, the IRS also issued notice 2008-2 asking for comments on the appropriate tax treatment of instruments such as the equity and commodity ETNs. The IRS has not issued additional guidance on this issue.

What is Barclays’ position about the tax status of equity, fixed income, leveraged, commodity and certain alternatives ETNs

Barclays is aligned with the Securities Industry and Financial Markets Association (SIFMA). We believe that the tax treatment of an investment product should be driven by the product’s attributes. Mutual funds and ETNs are taxed differently because they are fundamentally different products. Investors who buy shares in a mutual fund own the underlying securities and receive dividend income from those securities annually, which is taxable. ETN investors do not own underlying securities and receive no dividends while holding the ETN.

What is the tax treatment of iPath ETNs in the event of an automatic termination or issuer redemption (applicable to certain iPath ETNs)

Investors should generally recognize capital gain or loss upon the sale, early redemption or maturity of their ETNs in an amount equal to the difference between the amount they receive at such time and their tax basis in the ETNs. For the tax implications of purchasing replacement securities offering similar exposure, including the potential application of the wash sale rules, please consult a tax professional.

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Barclays Company Capital and its Inc. affiliates and do its not affiliates provide and tax advice BlackRock and nothing Fund Distribution contained discussion herein should of U. be S. tax construed matters to contained be tax advice. herein (including Please be any advised attachments) that any purpose (i) is not of intended avoiding or U. written S. tax-related to be used, penalties; and cannot and (ii) be was used, written by you to support for the herein. the promotion Accordingly, or marketing you should of the seek transactions advice or based other on matters your addressed particular circumstances from an independent tax advisor. iPath ©2006, logo 2011 are Barclays registered Bank PLC. trademarks All rights of reserved. Barclays iPath, Bank iPath PLC. ETNs All and other the used trademarks, with the servicemarks permission, of or their registered respective trademarks owners. 598-68TP-6/11 are the property, and

iP-0386-0711

FIND YOUR iPATH 1– 877–764–7284 www.iPathETN.com

FIND YOUR iPATH 1–877–764–7284 www.iPathETN.com