CRS and FATCA Notice

1. Introduction

This Notice outlines the obligations of MAXNAM SOLUTIONS LTD. ("MAXNAM," "the Company," "we," or "us") under the Foreign Account Tax Compliance Act ("FATCA") and the OECD Common Reporting Standard ("CRS"), as implemented under Canadian law and the laws of the Province of Ontario.

As a financial institution providing financial accounts and payment services, MAXNAM acts as a data controller and is subject to international tax compliance frameworks that mandate the collection, processing, and, where applicable, the automatic exchange of certain information with tax authorities.

This Notice applies to all account holders and customers who are subject to the requirements of FATCA and/or CRS under applicable legislation.

2. Legal Framework

FATCA is legislation enacted by the United States Department of the Treasury and the Internal Revenue Service ("IRS") to promote tax compliance among U.S. persons holding financial accounts outside the United States.

In Canada, FATCA is implemented through the Agreement between the Government of Canada and the Government of the United States of America to Improve International Tax Compliance through Enhanced Exchange of Information under FATCA (the "Intergovernmental Agreement" or "IGA"). Under this agreement, Canadian financial institutions are required to report certain information regarding accounts held by U.S. persons to the Canada Revenue Agency ("CRA"), which subsequently exchanges that information with the IRS.

CRS was developed by the Organisation for Economic Co-operation and Development ("OECD") to establish a global framework for the automatic exchange of financial account information between participating jurisdictions.

In Canada, CRS is implemented under the Income Tax Act and associated regulations, requiring financial institutions to identify accounts held by tax residents of jurisdictions that have adopted CRS and to report such information to the CRA for exchange with the relevant foreign tax authorities.

3. Information Collected and Processed

To comply with FATCA and CRS requirements, MAXNAM collects and may exchange certain information with tax authorities where applicable.

• Full name of the account holder.
• Residential address.
• Country or countries of tax residence.
• Tax Identification Number(s) ("TIN") issued by the country or countries of tax residence, including, where applicable, a U.S. TIN.
• Place and date of birth.
• Account number or another identifying reference for the account.
• Account balance or value as of December 31 of each calendar year during which the account is maintained.

3.1 Processing Purpose and Retention

This information is processed for the purposes of fulfilling the Company's obligations under FATCA and CRS and is retained only for as long as necessary to meet these legal requirements.

4. Exchange of Information

If an account holder qualifies as a Specified U.S. Person under FATCA or a Reportable Person under CRS, MAXNAM, acting as a reporting financial institution, will transmit the relevant account information to the Canada Revenue Agency (CRA).

The CRA will subsequently exchange that information with the U.S. Internal Revenue Service (IRS) in the case of FATCA, or with the competent tax authorities of the account holder's country or countries of tax residence that are participating jurisdictions under CRS.

Reporting occurs for each calendar year during which the account holder is classified as a reportable account holder under the applicable framework.

5. Customer Obligations

Under FATCA and CRS, account holders are obligated to provide accurate and complete information to MAXNAM, including updates or additional information that may be required from time to time.

• Self-certification of tax residency status.
• Provision of Tax Identification Numbers (TINs).
• Submission of relevant IRS forms, such as the W-8 or W-9 series, or equivalent documentation.

5.1 Consequences of Non-Disclosure

Failure to provide the requested information in a timely manner may result in the account being treated as reportable under FATCA or CRS, and MAXNAM may be required to report the account information to the CRA accordingly.

MAXNAM does not verify the accuracy or completeness of any TIN or other information supplied by the customer and assumes no liability for errors in customer-provided information or for any loss arising from reliance on that information.

6. Data Subject Rights

Account holders have the right to access the information that has been exchanged with tax authorities and to request the rectification of inaccurate or incomplete information.

To exercise these rights, account holders should follow the procedures set out in the legal agreement governing their relationship with MAXNAM or contact the Company directly at support@maxnam.com.

7. About CRS

CRS was developed by the OECD to facilitate the automatic exchange of financial account information between participating jurisdictions. The European Union incorporated CRS through Council Directive 2014/107/EU ("DAC2"), requiring EU Member States to exchange information on financial accounts held by residents of other EU jurisdictions.

Under CRS, MAXNAM is required to identify whether a customer is a tax resident of a jurisdiction other than Canada. To fulfill this obligation, the Company collects information regarding the customer's tax residency status during onboarding and may request additional details as needed.

A complete list of CRS-participating countries is available on the OECD website: https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/crs-by-jurisdiction/

8. About FATCA

FATCA aims to prevent U.S. persons from using non-U.S. financial institutions to avoid U.S. taxation on their income and assets. The legislation became effective on July 1, 2014.

FATCA applies to both personal and business customers who are classified as U.S. persons for U.S. tax purposes, as well as certain entities with U.S. ownership.

• U.S. citizens, including those born in the United States who reside abroad and have not renounced citizenship.
• U.S. lawful permanent residents (green card holders).
• Individuals meeting the substantial presence test under U.S. tax law.
• U.S. corporations, partnerships, estates, and trusts.

8.1 FATCA Reporting

If a customer fails to provide requested documentation, such as a valid U.S. TIN or evidence of non-U.S. status, MAXNAM may be required to treat the account as reportable for FATCA purposes.

Under the Canada-U.S. Intergovernmental Agreement, MAXNAM reports information on accounts held by U.S. persons to the Canada Revenue Agency, which then shares this information with the IRS.

9. Key Differences Between CRS and FATCA

While FATCA and CRS share the common objective of combating tax evasion through automatic exchange of information, their scopes differ in important ways.

• Scope: FATCA focuses on U.S. persons, while CRS applies to tax residents of participating jurisdictions globally.
• Reporting mechanism: FATCA is based on a bilateral agreement between Canada and the United States, while CRS operates as a multilateral framework among participating jurisdictions.
• Applicable forms: FATCA commonly relies on IRS Forms W-8 and W-9, while CRS relies on self-certification of tax residency.

10. Tax Identification Number (TIN)

A Tax Identification Number (TIN) is a unique identifier issued by a jurisdiction to taxpayers for tax administration purposes.

If a customer is in the process of obtaining a TIN, they should notify MAXNAM as soon as the number becomes available so that records may be updated accordingly. Where a jurisdiction does not issue TINs, the Company will accept alternative documentation as permitted by applicable regulations.

11. Additional Resources

For further information regarding FATCA, CRS, or tax residency, customers may consult the following resources.

• OECD Automatic Exchange of Information Portal: https://www.oecd.org/tax/automatic-exchange/crs-implementation-and-assistance/
• U.S. Internal Revenue Service (IRS) - FATCA: https://www.irs.gov/
• Canada Revenue Agency (CRA) - International Tax Compliance: https://www.canada.ca/en/revenue-agency.html

11.1 Professional Advice

MAXNAM does not provide tax or legal advice. Customers should consult their own tax advisors regarding their specific tax residency status and reporting obligations.

12. Contact Information

For questions regarding this Notice or MAXNAM's FATCA and CRS compliance practices, please contact MAXNAM SOLUTIONS LTD. at support@maxnam.com.