IDTI » Topics » Certain U.S. Federal Income Tax Considerations

This excerpt taken from the IDTI 8-K filed May 20, 2009.

Certain U.S. Federal Income Tax Considerations


U.S. IRS CIRCULAR 230: To ensure compliance with IRS Circular 230, you are hereby notified that: (i) any discussion of U.S. federal tax issues in this Circular (including any attachments) is not intended or written to be relied upon, and cannot be relied upon by you, for the purpose of avoiding penalties that may be imposed on you under the Internal Revenue Code of 1986, as amended; (ii) such discussion is written in connection with the promotion or marketing of the transactions or matters addressed herein; and (iii) you should seek advice based on your particular circumstances from an independent tax advisor.

The following is a summary of certain material U.S. federal income tax consequences to a U.S. Holder (as defined below) arising from and relating to the Arrangement. This summary is not applicable to persons holding Tundra RSUs, Tundra Options or other rights to acquire Tundra Shares and any U.S. Holder that holds



any of the foregoing should consult their own independent tax advisor regarding the U.S. federal income tax consequences to them of the Arrangement, having regard to such holder’s particular circumstances.

This summary is not intended to constitute a complete description of all the potential U.S. federal income tax consequences, or any other tax consequences, that may apply to a U.S. Holder as a result of the Arrangement. In addition, this summary does not take into account the individual facts and circumstances of any particular U.S. Holder that may affect the U.S. federal income tax consequences applicable to such holder. Accordingly, this summary is not intended to be, and should not be construed as, legal or U.S. federal income tax advice with respect to any U.S. Holder. Each U.S. Holder should consult its own independent tax advisor regarding the U.S. federal income tax consequences of the Arrangement.

No legal opinion from U.S. legal counsel or ruling from the Internal Revenue Service (the “IRS”) has been requested, or is expected to be obtained, regarding the U.S. federal income tax consequences described below. This summary is not binding on the IRS, and the IRS is not precluded from taking a position that is different from the positions described in this summary. Because the authorities on which this summary is based are subject to various interpretations, the IRS and the U.S. courts could disagree with one or more of the positions described in this summary.

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