TOP Ships Announces Likely PFIC Status for 2009
20 Oktober 2009 - 10:05PM
PR Newswire (US)
ATHENS, Greece, Oct. 20 /PRNewswire-FirstCall/ -- TOP Ships Inc.
(NASDAQ: TOPS) (the "Company") today announced that it expects to
be treated as a passive foreign investment company, or PFIC, for
U.S. federal income tax purposes for 2009. Generally, a foreign
corporation will be treated as a PFIC for U.S. federal income tax
purposes if either (1) at least 75% of its gross income for any
taxable year consists of certain types of "passive income" or (2)
at least 50% of the average value of the corporation's assets
produce or are held for the production of those types of "passive
income." Based on the application of these criteria, management
believes that the Company and certain of its subsidiaries will
likely be treated as a PFIC for the 2009 taxable year. The
Company's classification as a PFIC may have adverse U.S. federal
income tax consequences to U.S. taxable shareholders of the
Company. Under the PFIC rules, a U.S. shareholder that makes a
Qualified Electing Fund, or QEF election, must report each year for
U.S. federal income tax purposes his pro rata share of our ordinary
earnings and our net capital gain, if any, for our taxable year
that ends with or within the taxable year of such holder,
regardless of whether or not distributions were received from us by
the shareholder. The shareholder's adjusted tax basis in the common
stock will be increased to reflect taxed but undistributed earnings
and profits. Distributions of earnings and profits that had been
previously taxed will result in a corresponding reduction in the
adjusted tax basis in the common stock and will not be taxed again
once distributed. A shareholder making a QEF election would
generally recognize capital gain or loss on the sale, exchange or
other disposition of the Company's common stock. A U.S. shareholder
would make a QEF election with respect to any year that we are
treated as a passive foreign investment company by filing one copy
of IRS Form 8621 with his United States federal income tax return
and a second copy in accordance with the instructions to such form.
A U.S. shareholder will need to make a QEF election for the Company
and for each of its subsidiaries that is treated as a PFIC. We
intend to provide each U.S. shareholder with all necessary
information in order to make the QEF election for the Company and
each of its subsidiaries that is a PFIC for 2009. A U.S.
shareholder that does not make a QEF election (which election could
itself have adverse consequences for such shareholder) would be
liable to pay U.S. federal income tax at the then prevailing income
tax rates on ordinary income plus interest upon excess
distributions and upon any gain from the disposition of the
Company's common stock, as if the excess distribution or gain had
been recognized ratably over the shareholder's holding period of
such common stock. For further information, please read the
Company's Annual Report on Form 20-F for the fiscal year ended
December 31, 2008, filed with the U.S. Securities and Exchange
Commission on June 29, 2009, under the caption "Item 10.E - Tax
Consequences - United States Federal Income Taxation of U.S.
Holders - Passive Foreign Investment Company Status and Significant
Tax Consequences." In addition, as a result of being treated as a
PFIC for the 2009 taxable year, any dividends paid by the Company
during 2009 and 2010 will not be eligible to be treated as
"qualified dividend income," which may otherwise be eligible for
preferential tax rates in the hands of non-corporate U.S.
shareholders. As of the date of this release, our fleet consists of
13 vessels, six of which are employed on time charters and the
remaining seven vessels, including the six newbuilding vessels
delivered in 2009, are employed on bareboat charters. Vessels
employed on bareboat charters are considered to earn passive income
under the PFIC rules. Therefore, our youngest vessels which have
the highest asset values in our fleet and which provide a stable
revenue stream over the next seven to ten years also contribute to
our total assets employed in the production of passive income. It
is management's intention to take necessary steps in order to avoid
PFIC status for 2010 and future taxable years, such as expanding
our fleet through the purchase of non-passive income producing
assets. However, there can be no assurance that such remedial
measures will be effective to avoid PFIC status for 2010 or any
future taxable year. THIS ANNOUNCEMENT SHOULD NOT BE CONSIDERED TAX
ADVICE. INVESTORS ARE URGED TO CONSULT WITH THEIR OWN TAX ADVISORS
TO DETERMINE THE CONSEQUENCES OF OWNERSHIP OF OR INVESTING IN THE
COMPANY'S COMMON STOCK. About TOP Ships Inc. TOP Ships Inc.,
formerly known as TOP Tankers Inc., is an international provider of
worldwide seaborne crude oil and petroleum products and drybulk
transportation services. The Company operates a combined tanker and
drybulk fleet as follows: -- A fleet of eight double-hull Handymax
tankers and an average age of 2.5 years with a total carrying
capacity of approximately 0.4 million dwt, of which 76% are sister
ships. Two of the Company's Handymaxes are on time charter
contracts with an average term of 10 months with both of the time
charters including profit sharing agreements above their base
rates. Six of the Company's Handymax tankers are fixed on a
bareboat charter basis with an average term of 8.5 years. -- A
fleet of five drybulk vessels with a total carrying capacity of
approximately 0.3 million dwt and an average age of 8.5 years, of
which 47% are sister ships. All of the Company's drybulk vessels
have fixed rate employment contracts for an average period of 24
months. Forward Looking Statements Certain statements and
information included in this release constitute "forward-looking
statements" within the meaning of the Federal Private Securities
Litigation Reform Act of 1995. The Private Securities Litigation
Reform Act of 1995 provides safe harbor protections for
forward-looking statements in order to encourage companies to
provide prospective information about their business.
Forward-looking statements reflect our current views with respect
to future events and financial performance and may include
statements concerning plans, objectives, goals, strategies, future
events or performance, and underlying assumptions and other
statements, which are other than statements of historical facts.
The Company desires to take advantage of the safe harbor provisions
of the Private Securities Litigation Reform Act of 1995 and is
including this cautionary statement in connection with this safe
harbor legislation. The words "believe," "anticipate," "intends,"
"estimate," "forecast," "project," "plan," "potential," "may,"
"should," "expect," "pending" and similar expressions identify
forward-looking statements. Important factors that, in our view,
could affect the matters discussed in these forward-looking
statements include, general market conditions, including
fluctuations in charter rates and vessel values, changes in the
demand for our vessels, offers that may be received from third
parties, potential liability from pending or future litigation,
general domestic and international political conditions, and other
factors. Please see our filings with the Securities and Exchange
Commission for a more complete discussion of these and other risks
and uncertainties. Contact: Michael Mason (investors) Allen &
Caron Inc 212 691 8087 DATASOURCE: TOP Ships Inc. CONTACT:
Investors, Michael Mason of Allen & Caron Inc, +1-212-691-8087,
, for TOP Ships Inc. Web Site: http://www.topships.org/
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