Element Announces Adjusted Cost Base Allocation Following Reorganization



Element Fleet Management and ECN Capital announced estimates of the adjusted cost base allocation of the Element Fleet common shares and ECN Capital common shares for Canadian income tax purposes following the recent completion of the reorganization of Element Financial, through a statutory plan of arrangement.

Pursuant to the arrangement, and as outlined under the heading “Material Canadian Federal Income Tax Consequences to Shareholders” in Element’s Management Information Circular dated July 28, 2016, a number of steps were undertaken that led to the exchange of Element common shares for ECN Capital common shares and Element Fleet common shares.

Please note that while the Companies believe the allocation as outlined below is a reasonable allocation for Canadian income tax purposes, such allocation is not binding on either shareholders or the Canadian tax authorities, nor is this legal or tax advice. Shareholders should therefore consult their own tax advisors in light of their particular circumstances.

For purposes of the Income Tax Act (Canada), the estimated adjusted cost base to a resident participating shareholder (as defined in the Circular) of each Element common share held immediately prior to completion of the arrangement should be allocated as follows: 79.44% to the Element Fleet common share and 20.56% to the ECN Capital common share received by a resident participating shareholder pursuant to the arrangement.


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