BTC Development Corp. (the "Company")
may be considered a “passive foreign investment company” (“PFIC”) for U.S. federal income tax purposes. The following
information is provided to allow a shareholder of the Company (a "Shareholder") to make an election under Section 1295 of the
Internal Revenue Code to treat the Company as a Qualified Electing Fund (“QEF Election”) for U.S. federal income tax purposes.
The QEF Election is optional and can only be made by the Shareholder. The Company is unable to make this election on behalf of the Shareholder.
Please note that a QEF Election may not be recognized for state income tax purposes in some states. The PFIC rules are complex. Please
consult with your personal tax advisor to determine whether or not it is advisable for you to make a QEF Election with respect to your
investment in the Company.
- This PFIC Annual Information statement applies to the tax period
of the Company:
| Beginning 1/1/2025 |
Ending 12/31/2025 |
- The Shareholder's per-unit, per-day information for the Company's
taxable period specified in paragraph (1) is provided in the below chart. We recommend that all U.S. taxpayers consult a tax advisor
concerning the overall tax consequences of their ownership in the Company and their U.S. tax reporting requirements.
| Fund Name (and name of any underlying funds if applicable) |
Ticker |
Ordinary Earnings (US$) |
Net Capital Gains (US$) |
| BTC Development Corp. |
BDCI |
0.0010364990 |
NONE |
- The amount of cash and fair market value of other property distributed
or deemed distributed by the Company to the Shareholder during the Company's taxable period specified in paragraph (1) is as follows:
| Cash: |
NONE |
| Fair Market Value of Property: |
NONE |
- The Company will permit the Shareholder to inspect and copy
the Company's permanent books of account, records, and such other documents as may be maintained by the Company that are necessary to
establish that PFIC ordinary earnings and net capital gain, as provided in Section 1293(e) of the Internal Revenue Code, are computed
in accordance with U.S. income tax principles, and to verify these amounts and the Shareholder’s pro rata share thereof.
| BTC Development Corp. |
| Date: |
February 24, 2026 |
By: |
/s/ R. Maxwell Smeal |
| Title: |
Chief Financial Officer |
Additional Information
The
following additional information is supplied to enable the Shareholder to complete IRS Form 8621:
(Please
note: a Shareholder may have additional filing disclosures including, but not limited to, Forms 926, 5471, and/or 8938 as a result of
the Shareholder’s investment in the Company. Please consult your tax advisor.)
| Address of the PFIC: |
2929
Arch Street, Suite 1703 |
| Philadelphia, PA 19104 |
| Taxpayer Identification Number: |
98-1816717 |
| Country of Incorporation: |
Cayman Islands |
| Date of Incorporation: |
4/3/2023 |
Source: BTC Development Corp.. This release was filed with the U.S. Securities and Exchange Commission on Feb 24, 2026 and is reproduced here as issued. View the filing.