Investors

Form 8621

Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund

Terrafina qualifies as passive foreign investment company ("PFIC") for U.S. tax purposes. This entity will permit the shareholder(s) to inspect and copy its permanent books of account, records, and such other documents as may be maintained by the corporation that are necessary to establish the PFIC's ordinary earnings and net capital gain, as provided in section 1293(e) of the Internal Revenue Code, are computed in accordance with U.S. income tax policies.

Generally, a U.S. person that is a direct or indirect shareholder of a PFIC must file Form 8621 for each tax year in which that U.S. person recognizes gain on a direct or indirect disposition of PFIC stock, receives certain direct or indirect distributions from a PFIC, or is making an election reportable in Part I of the form. A separate Form 8621 must be filed for each PFIC in which stock is held.

Please consult your tax advisor prior to completing and filing Form 8621.

Based on available information you may qualify as a U.S. person who is a direct or indirect shareholder of a PFIC and may elect under section 1295 to treat the PFIC as a Qualified Electing Fund ("QEF"). A taxexempt organization that is not taxable under section 1291 may not make the election. In addition, a taxexempt organization that is a member of a domestic pass-through entity is not subject to a QEF election made by the pass-through entity.The income from Qualified Electing Fund (QEF), presented in the statement is calculated per 10,000 CBFI owned.

In a chain of ownership, only the first U.S. person that is a direct or indirect shareholder of the PFIC may make the election.

The following information is being provided to assist you in filing Form 8621.