Tax Information

IMPORTANT TAX NOTICE TO U.S. SHAREHOLDERS RELATED TO AN INVESTMENT IN ALTIUS RENEWABLE ROYALTIES CORP.

‍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 RENEWABLE ROYALTIES CORP.

PFIC Status

This statement is provided for shareholders of Altius Renewable Royalties Corp. (“ARR”) who are United States persons (“U.S. Shareholders”) for purposes of the Internal Revenue Code of 1986, as amended (the “Code”). ARR believes, on a more-likely-than-not basis, that it was not 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, 2023 (the “2023 Tax Year”). The classification of ARR under PFIC rules depends, in part, on whether certain of its income qualifies for the exemption for active business gains for the purpose of the asset and income tax tests. The expectation of ARR regarding status for the 2023 Tax Year does not have a bearing on future years, as the analysis of income and assets has to be performed every year.

The determination of whether a corporation was, or will be, a PFIC for a particular tax year depends, in part, on the application of complex U.S. federal income tax rules, which are subject to differing interpretations. In addition, whether any corporation will be a PFIC for any tax year depends on the assets and income of such corporation over the course of each such tax year and, as a result, ARR’s PFIC status for the current year and future years cannot be predicted with certainty. We recommend U.S. Shareholders consult with their advisors regarding PFIC status.