IMPORTANT NOTICE TO U.S. SHAREHOLDERS RELATED TO THEIR INVESTMENT IN
TRIPLE FLAG PRECIOUS METALS CORP.
This information is provided for shareholders who are U.S. taxpayers. It may
not be relevant for other individuals.
THE U.S. TAX RULES REGARDING PFICS ARE VERY COMPLEX AND INVESTORS ARE
STRONGLY URGED TO CONSULT THEIR OWN TAX ADVISORS REGARDING THE U.S. TAX
CONSEQUENCES OF THE PFIC RULES WITH REGARD TO THEIR INVESTMENT IN TRIPLE
FLAG PRECIOUS METALS CORP.
PFIC Status for Tax Year 2024
Triple Flag Precious Metals Corp. (“Triple Flag”) 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 its tax year ended December 31,
2024. However, the determination as to whether any 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 and uncertainty. In addition, there is limited
authority on the application of the relevant PFIC rules to entities such
as Triple Flag and its subsidiaries. Accordingly, there can be no
assurance that the U.S. Internal Revenue Service will not challenge Triple
Flag’s views concerning its PFIC status. In addition, whether any
corporation 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, Triple Flag’s
PFIC status for its current tax year and any future tax year cannot be
predicted with certainty.
INVESTORS SHOULD CONSULT THEIR OWN TAX ADVISORS REGARDING THE PFIC STATUS
OF TRIPLE FLAG AND ITS SUBSIDIARIES.
The foregoing statements are qualified in their entirety by the discussion
set forth under the heading “United States Federal Income Tax
Considerations” in the Annual Report of TRIPLE FLAG on Form 40-F filed
with the United States Securities and Exchange Commission on March 28,
2025.