"There are also tax complications in the US of owning 'real'...

"There are also tax complications in the US of owning 'real' foreign securities (i.e. foreign account reporting requirements) which means that holding just one foreign share is more hassle than its worth. Maybe Vraetorian can give us more insight. "
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Hi Maxi, yes you'd be correct in saying there are complications/consequences for U.S Holders.

First off, there are 20 pages just dedicated to income tax consequences of the arrangement. I'll find a part that helps to summarize it. But, If there are any further questions.. I'll do my best to find the answers in the book.


So the question was:

-What are the United States federal income tax consequences of the Arrangement to Lithium One Shareholders?
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"The exchange of LIthium One common shares for galaxy shares pursuant to the arrangement will be taxable transaction for U.S. HOlders. Accordingly, Lithium One shareholders that are U.s. Holders that exchange their lithium One Common Shares for Galxy shares will generally recognize capital gain or loss on such exchange equal to the difference between the "amount realized" and the U.S. Holder's aggregate adjusted tax basis in the Lithium one Common Shares exchanged. The "amount realized" will equal the fair market value of the Galaxy Shares received by such U.S. Holder. If Lithium One was a PFIC at any time during a U.S. Holder's holding period for the Lithium One Common Shares, any gain recognized may be treated as ordinary income and any tax due may include an interest charge. Lithium One expects to be a PFIC for the tax year in which the Arrangement occurs.

All U.S. holders of Lithium One Common Shares are urged to consult their own tax advisors regarding the specific U.S. federal income tax consequences of the Arrangement that are applicable to them. No advance income tax ruling has been sought or obtained with respect to the Arrangement.

See "Certain United States Federal Income Tax Considerations" for the definitions of the terms "U.S. Holder" and "PFIC", and for a general summary of certain material U.S federal income tax considerations arising from the Arrangement, which qualifies the information set forth above."

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This one section was only 1/4 of a page long. As you may guess, it was a headache reading this textbook, which is 2 inches thick and written the same way throughout.
-V