POZEN and Tribute remain committed to combining their respective businesses and are considering a Canadian domicile for Aralez Pharmaceuticals ("Aralez"), the new parent entity for the combined companies. With the planned business operations in Ireland, Canada and the United States, the Canadian domicile offers substantially similar financial, tax and competitive advantages to an Irish domicile, and will benefit from Tribute's business foundation and strong presence in Canada where Tribute was incorporated and from where it has always operated. The parties further believe that a Canadian domicile will be in compliance with the new Treasury Department Guidance and are working diligently and expeditiously on an alternative transaction structure that would be in the best interest of their respective securityholders, and the parties are further considering the Treasury Department Guidance as they continue to arrive at this alternative transaction structure.
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