I B AI B A Minimizing withholding tax is a critical consideration in structuring Upper Tier II Repatriation of funds Interest payments to Non-resident
{"Image DocumentName": "There were a number of structural complexities that made an offshore issuance attractive for Chinatrust Bank", "Image ImageDescription": "Case study. JPMorgan used offshore branch structure in March 2005 to issue International Tier 2 (first ever UT2 out of Taiwan) for Chinatrust using the Hong Kong branch as the issuing entity. Because the Hong Kong branch was the same legal entity as the Taiwanese company, the issue qualified as Tier 2 capital. First ever international Bonds offering from any Taiwan company. First issuance of Upper Tier II qualifying capital in the international markets by a Taiwan Bank. Debut US  Bonds offering for Chinatrust Commercial Bank Co., Ltd., the largest private commercial bank in Taiwan. Transaction priced through initial price guidance of 90bp area, and within the revised price guidance of 85\u201487bp. Deal generated approximately  3.9 billion of orders from 155 accounts and was nearly 13 times oversubscribed on its initial announced issuance size of  300 million. On the back of the over- whelming strong demand, the transaction was upsized to US 500million. JPMorgan played a critical role in working closely with the Company and regulators to establish Upper Tier II and the appropriate issuance structure for international Bank Capital transactions from Taiwan. JPMorgan is the Sole Bookrunner and Lead Manager for the transaction. One legal entity. Mar  500mm. Chinatrust. Lead managed CT\u2019s  500mm Upper Tier II (RegS/144A) offering. Global Co-ordinator and Sole Bookrunner. Chinatrust Taiwan. Chinatrust HK branch.   500mm. T 2 Bonds.   500mm Bond proceeds. Investors. 53.", "Image XResolution": "37", "Image YResolution": "37", "Image ResolutionUnit": "Pixels/Centimeter", "Image Software": "SlidePlayer", "Image YCbCrPositioning": "Centered"}