Disclaimer:Any tax advice in this document should be considered in the context of the overall tax services we are providing to you. Preliminary advice should not be relied upon and may not provide penalty protection. This document is based on the completeness and accuracy of facts, assumptions, and representations that were provided to us, and on which we relied. We considered tax authorities that are subject to change, possibly even retroactively, and any such changes could affect the conclusions herein. Unless otherwise agreed, we will not update this document for later changes or modifications to the authorities discussed, and we will not take into account any updated, new, or additional information. This document is intended for WithumSmith + Brown’s client, subject to the terms and conditions of a written engagement letter, and no other person or organization may rely on it.