The fiscal year for all Prime Infrastructure entities is currently from 1 July to 30 June. For US tax purposes, PIHL and PIT 2 are classified as corporations and PIT will be classified as a corporation for fiscal years commencing on 1 July 2009. PIHL and PIT are not expected to be ‘passive foreign investment corporations’ (PFIC) for US tax purposes. PIT 2 is expected to be a PFIC for the fiscal year ended 30 June 2010. While PIT 2 is a PFIC, all income attributed to US investors through their investment in PIT 2 is expected to be distributed to investors within 3 months of the end of the fiscal year in which the income is earned.