Report of Organizational Actions Affecting Basis of Securities Oban Mining Corporation Acquisition of NioGold Mining Corp.

On March 11, 2016, Oban Mining Corporation (“Oban”) completed the acquisition of all of the outstanding common shares of NioGold Mining Corp. (“NioGold”) in exchange for common shares of Oban (the “Exchange”) pursuant to a plan of arrangement.  Pursuant to the Exchange, each former NioGold shareholder received 0.4167 common shares of Oban in exchange for each common share of NioGold.
As described in the management information circular of NioGold, dated February 3, 2016, (the “Arrangement Circular”) and subject to the application of the passive foreign investment company rules, the Exchange of NioGold shares for Oban shares was expected to qualify as a reorganization within the meaning of Section 368(a) of the U.S. Internal Revenue Code of 1986, as amended (the “Code”).  Assuming the exchange of NioGold shares for Oban shares qualifies as a reorganization under Section 368(a) of the Code, and subject to the application of the passive foreign investment company rules, NioGold shareholders generally did not recognize any gain or loss on the exchange of their shares for Oban shares. The aggregate basis of the Oban shares received in the exchange should be the same as the aggregate basis of the NioGold shares for which they are exchanged. The holding period of Oban shares received in the exchange includes the holding period of the NioGold shares for which they are exchanged. A holder’s tax basis and holding period in its Oban shares received must be determined with reference to each block of NioGold shares (generally shares acquired at different times or at different costs) for which they were exchanged.
For more information, please see the discussion entitled “CERTAIN U.S. FEDERAL INCOME TAX CONSIDERATIONS FOR U.S. HOLDERS” in the Arrangement Circular.

Describe the quantitative effect of the organizational action on the basis of the security in the hands of the U.S. taxpayer as an adjustment per share or as a percentage of old basis.

Assuming the exchange of NioGold shares for Oban shares qualifies as a reorganization under Section 368(a) of the Code, and subject to the application of the passive foreign investment company rules, the aggregate basis of the Oban shares received in the exchange should be the same as the aggregate basis of the NioGold shares for which they are exchanged. A holder’s tax basis in its Oban shares received must be determined with reference to each block of NioGold shares (generally shares acquired at different times or at different costs) for which they were exchanged.
For more information, please see the discussion entitled “CERTAIN U.S. FEDERAL INCOME TAX CONSIDERATIONS FOR U.S. HOLDERS” in the Arrangement Circular.

Describe the calculation of the change in basis and the data that supports the calculation, such as the market values of securities and the valuation dates.

Assuming the exchange of NioGold shares for Oban shares qualifies as a reorganization under Section 368(a) of the Code, and subject to the application of the passive foreign investment company rules, the aggregate basis of the Oban shares received in the exchange should be the same as the aggregate basis of the NioGold shares for which they are exchanged. A holder’s tax basis in its Oban shares received must be determined with reference to each block of NioGold shares (generally shares acquired at different times or at different costs) for which they were exchanged.
For more information, please see the discussion entitled “CERTAIN U.S. FEDERAL INCOME TAX CONSIDERATIONS FOR U.S. HOLDERS” in the Arrangement Circular.

List the applicable Internal Revenue Code section(s) and subsection(s) upon which the tax treatment is based.


Sections 368(a), 354, 356, 358, and 1221.  The passive foreign investment company rules of Sections 1291-1298 may also be relevant.

Assuming the exchange of NioGold shares for Oban shares qualifies as a reorganization under Section 368(a) of the Code, and subject to the application of the passive foreign investment company rules, NioGold shareholders generally did not recognize any loss on the exchange of their shares for Oban shares.
For more information, please see the discussion entitled “CERTAIN U.S. FEDERAL INCOME TAX CONSIDERATIONS FOR U.S. HOLDERS” in the Arrangement Circular.