Incredimail 2014 Annual Report Download - page 86

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The rules applicable to owning shares of a PFIC are complex, and each prospective purchaser who would be a U.S. Holder should
consult with its own tax advisor regarding the consequences of investing in a PFIC.
Tax Consequences for Non-U.S. Holders of Ordinary Shares
Except as described in "Information Reporting and Back-up Withholding" below, a Non-
U.S. Holder of our ordinary shares will not be subject to
U.S. federal income or withholding tax on the payment of dividends on, and the proceeds from the disposition of, our ordinary shares, unless, in
the case of U.S. federal income taxes:
Information Reporting and Backup Withholding
U.S. Holders generally are subject to information reporting requirements with respect to dividends on, or proceeds from the disposition
of, our ordinary shares. In addition, a U.S. Holder may be subject, under certain circumstances, to backup withholding (currently, at a rate of up
to 28%) with respect to dividends paid on, or proceeds from the disposition of, our ordinary shares unless the U.S. Holder provides proof of an
applicable exemption or correct taxpayer identification number, and otherwise complies with the applicable requirements of the backup
withholding rules. A U.S. Holder of our ordinary shares who provides an incorrect taxpayer identification number may be subject to penalties
imposed by the IRS. Amounts withheld under the backup withholding rules are not an additional tax and may be refunded or credited against the
U.S. Holder’s U.S. federal income tax liability, provided the required information is furnished to the IRS.
Non-U.S. Holders generally are not subject to information reporting or backup withholding, provided that the Non-U.S. Holder
provides a taxpayer identification number, certifies to its foreign status, or establishes another exemption to the information reporting or backup
withholding requirements.
Certain U.S. holders (and to the extent provided in IRS guidance, certain non-
U.S. holders) who hold interests in "specified foreign
financial assets" (as defined in Section 6038D of the Code) are generally required to file an IRS Form 8938 as part of their U.S. federal income
tax returns to report their ownership of such specified foreign financials assets, which may include our common shares, if the total value of those
assets exceed certain thresholds. Substantial penalties may apply to any failure to timely file IRS Form 8938. In addition, in the event a holder
that is required to file IRS Form 8938 does not file such form, the statute of limitations on the assessment and collection of U.S. federal income
taxes of such holder for the related tax year may not close until three years after the date that the required information is filed. Holders should
consult their own tax advisors regarding their tax reporting obligations.
F. DIVIDENDS AND PAYING AGENTS
Not applicable.
G. STATEMENT BY EXPERTS
Not applicable.
H. DOCUMENTS ON DISPLAY
` You may request a copy of our U.S. SEC filings, at no cost, by writing or calling us at Perion Network Ltd., 26 HaRokmim Street,
Holon 5885849, Israel, Attention: Yacov Kaufman, Telephone: +972-73-3981000. A copy of each report submitted in accordance with
applicable U.S. law is available for public review at our principal executive offices. In addition, our filings with the SEC may be inspected
without charge at the SEC’s Public Reference Room at 100 F Street, N.E., Washington, D.C. 20549. Information on the operation of the Public
Reference Room can be obtained by calling the SEC at 1-800-SEC-0330. Our SEC filings are also available to the public from the SEC’s
website at www.sec.gov.
• the item is effectively connected with the conduct by the Non-
U.S. Holder of a trade or business in the United States and (i) in the
case of a resident of a country which has a treaty with the United States, the item is attributable to a permanent establishment, or
(ii) in the case of an individual, the item is attributable to a fixed place of business in the United States; or
• the Non-
U.S. Holder is an individual who holds the ordinary shares as a capital asset and is present in the United States for 183
days or more in the taxable year of the disposition, and certain other conditions are met.
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