The document discusses the U.S. federal income tax implications for U.S. Holders of Mobileye shares in relation to the company's status as a Passive Foreign Investment Company (PFIC) and the tax consequences of the Post-Offer Reorganization. It highlights the potential adverse tax consequences for U.S. Holders if Mobileye is considered a PFIC and advises consulting tax advisors. The document also covers the possibility of Israeli withholding taxes and the availability of foreign tax credits for U.S. Holders. Additionally, it provides a summary of certain Israeli tax consequences related to the Offer and Post-Offer Reorganization, based on the Israel Income Tax Ordinance and a ruling obtained from the Israel Tax Authority (ITA).
documents/EFTA01369897.pdf
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