PFIC Status
The application of the U.S. tax rules governing a passive foreign investment company (“PFIC”) within the meaning of Section 1297 of the Internal Revenue Code of 1986, as amended, to companies like Ecora Resources PLC and each of its non-U.S. subsidiaries (collectively, the “Ecora Entities”) is not entirely clear. While we believe the Ecora Entities should not be classified as a PFIC and that the operations of the Ecora Entities are not the type that the PFIC rules intended to encompass, the determination as to whether any individual Ecora Entity was, or will be, a PFIC for a particular year depends, in part, on the application of complex U.S. federal income tax rules, which are subject to differing interpretations and uncertainty. In addition, there is limited analysis regarding the application of the relevant PFIC rules to entities with active operations such as those of the Ecora Entities.
If any shareholder needs additional information with respect to the Ecora Entities potential status as a PFIC, please contact Ecora Resources PLC.