IMPORTANT TAX NOTICE TO U.S. SHAREHOLDERS RELATED TO AN INVESTMENT IN ALTIUS MINERALS CORPORATION
This information is provided for shareholders who are U.S. taxpayers. It may not be relevant for other persons.
THE U.S. TAX RULES REGARDING PFICS ARE VERY COMPLEX AND INVESTORS ARE STRONGLY URGED TO CONSULT THEIR OWN TAX ADVISOR REGARDING THE U.S. TAX CONSEQUENCES OF THE PFIC RULES TO THEIR INVESTMENT IN ALTIUS MINERALS CORPORATION.
Altius Minerals Corporation ("Altius Minerals") does not believe that Altius Minerals or any of its non-U.S. subsidiaries (collectively, the "Altius Entities") was a passive foreign investment company ("PFIC") within the meaning of Section 1297 of the Internal Revenue Code of 1986, as amended, for the tax year ended December 31, 2018 (the "2017 Tax Year").
The determination as to whether any Altius 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, whether any Altius Entity will be a PFIC for any tax year depends on its assets and income over the course of such tax year, and, as a result, the PFIC status of any Altius Entity for the 2018 Tax Year or for any future tax year cannot be predicted with certainty.
INVESTORS SHOULD CONSULT THEIR OWN TAX ADVISOR REGARDING THE PFIC STATUS OF THE ALTIUS ENTITIES.
The attached PFIC Annual Information Statements are being provided pursuant to the requirements of Treasury Regulation Section 1.1295-1(g)(1). These PFIC Annual Information Statements contain information to enable you, should you so decide after consultation with your tax advisor, to take the position for the 2017 Tax Year that one or more of the Altius Entities is a PFIC, and/or choose to elect to treat one or more of the Altius Entities as a qualified electing fund ("QEF").
- PFIC Annual Information Statement 2013
- PFIC Annual Information Statement 2014
- PFIC Annual Information Statement 2015
- PFIC Annual Information Statement 2016
- PFIC Annual Information Statement 2017
- PFIC Annual Information Statement 2018
The QEF election is generally made on IRS Form 8621 ("Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund") on or before the due date, including extensions, for the income tax return with respect to the tax year to which the election relates.
Under current U.S. law, a U.S. person who is a PFIC shareholder at any time during a particular tax year is required to file Form 8621. In addition, a U.S. person who owns PFIC stock through another U.S. person is also required to file Form 8621 in certain circumstances. Moreover, certain categories of U.S. shareholders must file information returns on IRS Form 8938 with respect to their investment in certain specified foreign financial assets if their total investments in such assets exceed $50,000. Altius Minerals Corporation stock may be treated as specified foreign financial assets for this purpose.
INVESTORS SHOULD CONSULT THEIR OWN TAX ADVISERS AS TO THE POSSIBLE APPLICATION TO THEM OF THIS FILING REQUIREMENT.