Passive Foreign Investment Company (“PFIC”) Information
Ribbit LEAP, Ltd.
March 3, 2023
From: Ribbit LEAP, Ltd. (the “Company”)
To: Holders of the Company’s Class A Ordinary Shares
Re: Passive Foreign Investment Company (“PFIC”) Information
The Company is providing certain information to you in connection with your investment in its Class A Ordinary Shares, Class B Ordinary Shares and Class L Ordinary Shares.
The Company meets the Internal Revenue Code definition of a passive foreign investment company (“PFIC”) for the taxable year ended November 21, 2022. The Company is hereby making available PFIC Annual Information Statements for Ribbit LEAP, Ltd. for their taxable year beginning on January 1, 2022 and ending on November 21, 2022 pursuant to the requirements of Treasury Regulation Section 1.1295-1(g)(1).
The PFIC Annual Information Statements contain information to enable you, should you choose, to elect to treat Ribbit LEAP, Ltd. as a Qualified Electing Fund (“QEF”).
A U.S. shareholder who makes a QEF election for Ribbit LEAP, Ltd. is required annually to include in his or her income or his or her pro rata share of the ordinary earnings and net capital gains for Ribbit LEAP, Ltd. The QEF election is made by completing and attaching Form 8621 for each PFIC to your federal income tax return filed by the due date of the return, including extensions.
U.S. shareholders are advised to consult with their tax advisors with respect to the 2022 PFIC Annual Information Statement.
The amounts shown on the enclosed PFIC Annual Information Statement represent the Company’s ordinary earnings and net capital gain for its tax year ended November 21, 2022. As you will see, the Company did NOT have any ordinary earnings or capital gain in the current year.
Very truly yours,
Cynthia McAdam
Chief Operating Officer
Please note that Ribbit LEAP, Ltd. is not acting and cannot act as your adviser. This discussion is for general information only and does not constitute legal and/or tax advice. You must consult your tax adviser to determine the tax consequences applicable to you.
Ribbit LEAP, Ltd.
Campbells Corporate Services, Willow House, 4th Floor
Cricket Square, Grand Cayman, Cayman Islands
EIN: 98-1549449
PASSIVE FOREIGN INVESTMENT COMPANY (“PFIC”) ANNUAL INFORMATION STATEMENT
FOR TAX YEAR ENDED NOVEMBER 21, 2022
(1) This PFIC Annual Information Statement applies to the Company’s tax year beginning January 1, 2022 to November 21, 2022 (the “current year”).
(2) The amounts below represent information for the entire class of 58,505,000 Class A Ordinary Shares, Class B Ordinary Shares and Class L Ordinary Shares outstanding at the end of the current year.
(3) The amount of cash and fair market value of other property distributed or deemed distributed by the Company to the entire class of shares shown above during the current year is as follows:
Cash: NONE
Fair market value of other property: NONE
(4) The Company will permit you to inspect and copy the Company’s permanent books of account, records and other documents as may be maintained by the Company that are necessary for you to establish that the amounts of the Company’s ordinary earnings and net capital gain are computed in accordance with U.S. income tax principles, and to verify these amounts and your pro rata shares thereof.
Ribbit LEAP, Ltd.
Cynthia McAdam
Chief Operating Officer
March 3, 2023