This statement is provided for shareholders of Gabriel who are United States persons for purposes of the U.S. Internal Revenue Code of 1986 (“IRC”) and the regulations thereunder. It is not relevant to other shareholders.

The collective Gabriel group of non-U.S. entities may collectively or individually be deemed to be classified as a Passive Foreign Investment Corporation ("PFIC”) as defined in Section 1297(a) of the IRC for the year ended December 31, 2019.

TO ENSURE COMPLIANCE WITH TREASURY DEPARTMENT CIRCULAR 230, YOU ARE HEREBY NOTIFIED THAT ANYTHING CONTAINED IN THIS NOTICE CONCERNING ANY FEDERAL TAX OR OTHER ISSUE IS NOT INTENDED OR WRITTEN TO BE USED, AND CANNOT BE USED, BY ANY PERSON OR ENTITY FOR THE PURPOSE OF (i) AVOIDING PENALTIES THAT MAY BE IMPOSED ON ANY TAXPAYER OR (ii) PROMOTING, MARKETING OR RECOMMENDING TO ANOTHER PARTY ANY MATTERS ADDRESSED HEREIN.

The PFIC Annual Information Statement listed below is being provided to you pursuant to the requirements of Treasury Regulation Section 1.1295-1(g) (1). The PFIC Annual Information Statement contains information to enable you or your tax advisor to prepare your tax return if you elect to treat any of the Gabriel [Resources Ltd] group of companies as a QEF.

A U.S. shareholder who makes a QEF election is required to annually include in his or her income his or her pro rata share of the ordinary earnings and net capital gains of the respective Gabriel  entity, whether or not that entity distributes any amounts to its shareholders.  If you do not elect to treat a Gabriel entity as a QEF, then if the Gabriel entity is a PFIC for any year during your holding period, adverse tax consequences could result.

The QEF election is generally made on Form 8621 ("Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund”) on or before the due date, including extensions, for the income tax return with respect to the tax year to which the election relates.

THIS INFORMATION IS PROVIDED IN ORDER TO ASSIST U.S. SHAREHOLDERS IN MAKING CALCULATIONS AND DOES NOT CONSTITUTE TAX ADVICE. THE U.S. TAX LAWS REGARDING PFICS ARE EXTREMELY COMPLEX AND SHAREHOLDERS ARE STRONGLY URGED TO CONSULT WITH THEIR OWN TAX ADVISORS REGARDING ANY DECISION TO MAKE (OR REFAIN FROM MAKING) ANY ELECTION THAT MAY BE AVAILABLE TO THEM BECAUSE ANY SUCH DECISION WILL DEPEND UPON THEIR OWN PARTICULAR TAX SITUATION AND MAY HAVE SIGNIFICANT AND CONTINUING U.S. TAX CONSEQUENCES.

Gabriel Resources Ltd. PFIC Annual Information Statement

Further information on PFIC rules is available on the internet at the Internal Revenue Service website.

Detailed information about PFICs and the QEF election: http://www.irs.gov/instructions/i8621/ch01.html

Instructions for completing IRS Form 8621: http://www.irs.gov/pub/irs-pdf/i8621/ch01.pdf

Form 8621: http://www.irs.gov/pub/irs-pdf/f8621.pdf