Based on our audited accounts and relevant market and shareholder data, we believe that we were not a PFIC for US federal income tax purposes with respect to the 2007 tax year.

The determination of PFIC status for the 2008 tax year can only be made at year end. Even if we are to be classified as a PFIC for the 2008 tax year, we should be able to rely on the change of business exception under Section 1298(b)(3) of the US Internal Revenue Code of 1986 and, in this regard, we confirm that we have received a private letter ruling from the US Internal Revenue Service to this effect. Please note, however, that our ability to rely on the private letter ruling depends on meeting certain factual conditions, including that we are not a PFIC for either of the two subsequent taxable years. As a result, if we rely on the change of business exception for 2008, we would become retroactively ineligible for such exception if we are found to be a PFIC for 2009 or 2010. We will not be able to inform you of such determination until early 2011. We suggest that investors take their own advice regarding the potential application of PFIC rules to the Company and any questions they may have on any US tax arising therefrom.