SandRidge Permian Trust Announces Quarterly Distribution and Distribution of Net Asset Sale Proceeds in August 2021 - Seite 4

Distributable income per unit (52,500,000 units issued and outstanding)

 

$

0.182

 

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(1) Represents the deposit of Avalon’s portion of the May 2021 distribution to Trust unitholders, pursuant to the Repayment Agreement dated as of March 1, 2021 between Avalon and the Trust.

 

 

(2) Represents the payment by Montare of the remaining unpaid portion of the missed May 2020 Quarterly Payment, together with accrued interest, as disclosed in the Trust’s Current Report on Form 8-K dated June 18, 2021.

 

Pursuant to Internal Revenue Code Section 1446, withholding tax on income effectively connected to a United States trade or business allocated to non-U.S. persons (“ECI”) should be made at the highest marginal rate. Under Section 1441, withholding tax on fixed, determinable, annual, periodic income from United States sources allocated to non-U.S. persons should be made at a 30% rate unless the rate is reduced by treaty. This is intended to be a qualified notice by SandRidge Permian Trust to nominees and brokers as provided for under Treasury Regulation Section 1.1446-4(b), and while specific relief is not specified for Section 1441 income, this disclosure is intended to suffice. Nominees and brokers should withhold at the highest marginal rate on the distribution made to non-U.S. persons. The Tax Cuts and Jobs Act (the “TCJA”) enacted in December 2017 treats a non-U.S. holder’s gain on the sale of Trust units as ECI to the extent such holder would have had ECI if the Trust had sold all of its assets at fair market value on the date of the sale of such Trust units. The TCJA also requires a transferee of Trust units to withhold 10% of the amount realized on the sale or exchange of such units (generally, the purchase price) unless the transferor certifies that it is not a non-resident alien individual or foreign corporation or another exception is available. Pursuant to final Treasury Regulations issued on October 7, 2020, this new withholding obligation will become applicable to transfers of units in publicly traded partnerships such as the Trust (which is classified as a partnership for federal and state income tax purposes) occurring on or after January 1, 2022.