Ann: Finalisation of Ivy Project divestment, page-17

Relevant excerpt copied below from an email sent to IvyKoin token holders on 1 July by Markie Bryant, owner of IvyKoin LLC. Note too that information regarding this tax exposure was made public by IvyKoin in a video published to token holders in April. The tax assessment raised on IvyKoin LLC by both Federal and State tax authorities would likely have been known in late 2018.

"Tax Obligation

The Ivy operating agreement stated that parent company CCA would absorb all ofIvy’s income tax liability for the year ending December 31, 2018. That taxliability is now estimated to be in the range of $2.7m - $3.5m.

CCA will absorb this tax liability, and Ivy will contribute $1.3m to CCA forincome taxes owed as a condition of CCA no longer having forward ownershipinterest in the company. Overall, this structure significantly minimizes taxliabilities for Ivy.

This negotiated arrangement saves Ivy between $1.4m and $2.2m in taxliabilities pertaining to the calendar year ended December 31, 2018, accordingto assessment by financial and tax experts."