## U.S. Federal Income Tax Considerations for U.S. Holders 

The following is a summary of certain U.S. federal income tax consequences of the ownership and disposition of our shares and ADSs as of the date hereof. The discussion set forth below is applicable to beneficial owners of our shares or ADSs that hold the shares or ADSs as capital assets and that are U.S. holders and non-residents of the Republic of China. You are a U.S. holder if you are: 

● an individual who is a citizen or resident of the United States; 

● a corporation or other entity taxable as a corporation for U.S. federal income tax purposes created or organized in or under the laws of the United States, any state thereof or the District of Columbia; 

● an estate the income of which is subject to U.S. federal income taxation regardless of its source; 

● a trust that is subject to the primary supervision of a court within the United States and one or more U.S. persons have the authority to control all substantial decisions of the trust; or 

● a trust that has a valid election in effect under applicable U.S. Treasury regulations to be treated as a U.S. person. 

This summary is based on the provisions of the Internal Revenue Code of 1986, as amended (the “Code”), and regulations, rulings and judicial decisions thereunder as of the date hereof, and such authorities may be replaced, revoked or modified so as to result in U.S. federal income tax consequences different from those discussed below. It is for general purposes only and you should not consider it to be tax advice. In addition, it is also based in part on representations made by the depositary and assumes that the deposit agreement and any related agreement will be performed in accordance with their terms. This summary does not represent a detailed description of all the U.S. federal income tax consequences to you in light of your particular circumstances and does not address the effects of any state, local or non-U.S. tax laws (or other U.S. federal tax consequences, such as U.S. federal estate or gift tax consequences). In addition, it does not represent a detailed description of the U.S. federal income tax consequences applicable to you if you are subject to special treatment under the U.S. federal income tax laws, including if you are: 

● a dealer in securities or currencies; 

● a trader in securities if you elect to use a mark-to-market method of accounting for your securities holdings; 

● a financial institution or an insurance company; 

● a regulated investment company; 

● a real estate investment trust; 

● a tax-exempt organization; 

● a person liable for alternative minimum tax; 

● a person holding shares or ADSs as part of a hedging, integrated or conversion transaction, constructive sale or straddle; 

● a person owning, actually or constructively, 10% or more of our voting stock; 

● a partnership or other pass-through entity for U.S. federal income tax purposes; or 

● a person whose “functional currency” is not the U.S. dollar. 

