PFIC Status (Information for US Investors)
We have concluded that Mainstay Medical International plc (“the Company”) is not a Passive Foreign Investment Company (”PFIC”) within the meaning of Section 1297(a) of the Code (US Tax Code) for the years ended December 31, 2017, December 31, 2016, December 31, 2015 and December 31, 2014.
We do note, however, that the Company may be a PFIC for the tax year ending December 31, 2018. The Company will complete PFIC analysis and post the conclusion on the Mainstay website for the tax year ending December 31, 2018 by June 30, 2019.
This information does not constitute tax advice. US shareholders are urged to consult their tax advisors with respect to the impact of this information on their tax returns.