Subject to the approval of the Board of Directors of Birchcliff, it is currently intended that dividends will be paid on the outstanding common shares on the last day of March, June, September and December in each year, or the following business day if the dividend payment date falls on a weekend or holiday.

Birchcliff advises that all common share dividends paid have been and will be designated as “eligible dividends” for the purposes of the Income Tax Act (Canada). This designation will apply until a notification of a change is posted on this website.

TAXATION INFORMATION FOR UNITED STATES RESIDENTS

The following information is provided to holders or potential holders of common shares of Birchcliff for general information purposes only. Investors are encouraged to seek advice from a qualified tax advisor in the United States to obtain guidance with respect to the appropriate tax treatment of their common share dividends.

It has been determined that Birchcliff should be a “Qualified Foreign Corporation” and, subject to the holding period requirements discussed below, the dividend portion of its distributions should be considered “Qualified Dividends” for U.S. federal income tax purposes, and thus be eligible for the reduced tax rates applicable to long-term capital gains.

In order to qualify for the preferential capital gains rate discussed above, a United States shareholder must own the common shares for more than 60 days during the 120-day period beginning 60 days before the ex-dividend date.

Pursuant to the Canada – U.S. Tax Treaty, distributions paid to residents of the United States may be subject to a 15% Canadian withholding tax on 100% of the gross distribution. Amounts paid for foreign taxes may be eligible for a foreign tax credit in the United States; however, the foreign tax credit is subject to numerous limitations imposed by the Internal Revenue Code which are not discussed in this summary.

This information is not intended to be an exhaustive discussion of all possible income tax consequences, but a general guideline. It is not intended to be legal or tax advice to any particular holder or potential holder of common shares of Birchcliff. The holders or potential holders of common shares of Birchcliff should consult their own tax advisors as to their particular tax consequences and reporting obligations.