About the Estimated Cost Base Allocation
On February 16, 2016, the Board of Directors of Element Financial approved a plan to separate Element Financial into two publicly-traded companies (the "Separation"): ECN Capital Corp. (“ECN Capital”), which comprised the commercial and vendor finance, rail finance and aviation finance businesses and Element Fleet Management Corp. (“the Company”) which included the fleet management business. On October 3, 2016, the Separation became effective and the Company distributed the shares of ECN Capital to the shareholders of the Company. For a shareholder looking to allocate his or her adjusted cost base of ECN Capital and Element Fleet Management Corp. common shares for Canadian income tax purposes, please refer to the table below. Please note that while the Company believes 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.
