Metaplanet Inc. Forum: Community User: runkle6

For our US shareholders: Metaplanet is currently assessing whether it may be classified as a passive foreign investment company (a “PFIC”).  We will be qualified as a PFIC for a given taxable year if 75 percent or more of our income for such taxable year is passive income, or 50 percent or more of our average assets held during such year produce passive income or are held for the production of passive income.  We expect that substantially all of our taxable income generated during the 2025 taxable year will be active income for these purposes.  Under existing Internal Revenue Service (“IRS”) guidance, we believe that substantially all of our goodwill can thus be characterized as an active asset for these purposes. Based upon the substantial amount of goodwill implied from our current market capitalization, less than half of our current assets would be viewed as producing passive income or be held for the production of passive income.  Given that there are uncertainties in the application of these rules, however, we recognize that it is possible the IRS may disagree with our determinations and may assert that we are a PFIC for the 2025 taxable year.  We are currently discussing with our advisors in order to provide more definitive guidance to shareholders, including whether we may provide information to enable shareholders to make a “qualified electing fund” election with respect to their Metaplanet shares, and expect to provide such additional guidance in the near future.  If a shareholder were to make a “qualified electing fund” election for a given taxable year, such shareholder would generally be required to include in their taxable income a pro rata share of our income and gains, substantially all of which currently consist of our income from options trading (Bitcoin Income Generation business line) and our hotel operations, and would not include unrealized gains from BTC holdings. We urge Metaplanet shareholders to consult their individual tax advisors. Thanks for your patience as we work on more definitive guidance for shareholders.