2021 PFIC Letter
If a shareholder has elected under Treas. Reg. 1.367(b)-3(c)(3) to include its pro rata share of earnings in profits in lieu of realized gain on the domestication transaction of Artius Acquisition Corp, the amount of allocable earnings and profits will be based on whether or not the shareholder has made a QEF election under IRC Sec. 1295 with respect to the Artius Acquisition Corp stock. If such election has been made, and the shareholder has included all such earnings under the QEF provisions, then the pro rata share of earnings and profits is 0. If the shareholder has not made such an election under IRC Sec. 1295 and/or has not included such earnings under the QEF provisions, then the shareholder would include 0.00389874 per share held on the date of the domestication transaction for which such election under 1.367(b)-3(c)(3) is being made.