U.S. Shareholder Tax Information — PFIC

This information is intended for shareholders of Gabriel Resources Ltd. (“Gabriel” or the “Company”) who are U.S. persons for U.S. federal income tax purposes.

Gabriel and certain of its non-U.S. subsidiaries may be classified as passive foreign investment companies (“PFICs”) under the U.S. Internal Revenue Code of 1986, as amended. PFIC status is determined separately for each entity and taxable year.

PFIC Annual Information Statement

The PFIC Annual Information Statement available below is provided to assist U.S. shareholders and their tax advisers in considering or maintaining a qualified electing fund (“QEF”) election and preparing the associated tax filings. It relates only to the entities and taxable year identified in the statement.

A QEF election generally requires a U.S. shareholder to include annually its proportionate share of the relevant PFIC’s ordinary earnings and net capital gains, whether or not distributions are received. The election is generally made on IRS Form 8621 by the applicable tax return deadline, including extensions. Separate elections and reporting may be required for indirectly held PFICs.

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