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IMPORTANT TAX NOTICE TO U.S. SHAREHOLDERS RELATED TO YOUR INVESTMENT IN FLOW CAPITAL CORP.
INVESTORS SHOULD CONSULT THEIR OWN TAX ADVISOR REGARDING THE PFIC STATUS OF FLOW CAPITAL.
This information is provided for shareholders who are U.S persons about the possible application of the rules relating to a Passive Foreign Investment Company (PFIC). It may not be relevant for other persons.
U.S investors are urged to consult their own tax advisors regarding the possible application of the PFIC rules and the consequences of holding securities of Flow Capital Corp. (Flow) if Flow is treated as a PFIC for any taxable year in which a U.S. investor holds its securities. U.S. persons include U.S. citizens (whether or not they are U.S. residents), certain individuals with U.S. permanent resident status, U.S. corporations, and certain U.S. trusts and estates. Investors should consult with a U.S. tax professional to determine whether they are United States persons.
PFIC Status for U.S. Investors
Flow Capital has not made, and does not expect to make, a determination as to whether it is or has ever been a PFIC. Consequently, there can be no assurance that Flow Capital has never been a PFIC or will not become a PFIC for any tax year during which U.S. investors hold securities of Flow Capital.
PFIC Annual Information Statement
The attached PFIC Annual Information Statements are being provided pursuant to 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 that Flow Capital is a PFIC for any tax year and/or to elect to treat Flow as a qualified electing fund for the purposes of the PFIC rules.
To ensure compliance with Treasury Department Circular 230, you are hereby notified that anything contained in this notice concerning any U.S. federal tax issues is not intended or written to be used, and it cannot be used by a U.S. holder, for the purpose of (i) avoiding federal tax penalties that may be imposed on the taxpayer or (ii) promoting, marketing or recommending to any party any matters addressed herein.
This information is provided in order to assist shareholders in making calculations and does not constitute tax advice. The U.S. tax laws regarding PFICs are extremely complex and shareholders are advised to consult their own tax adviser concerning the overall tax consequences of their respective investment in, and ownership of securities of, Flow Capital under U.S. federal, state, local and foreign law.
Further information in PFIC rules is available on the internet at the Internal Revenue Service website.