U.S. SHAREHOLDERS
The comment below provides a summary of the principal United States federal income tax consequences of the Distribution.

You are directed to consult your own tax advisor regarding the particular federal, foreign, state and local tax consequences of the Distribution.

TREATMENT OF THE DISTRIBUTION IN GENERAL
For U.S. federal income tax purposes, every distribution made by a corporation is made out of its earnings and profits to the extent thereof and from the most recently accumulated earnings and profits. The Distribution received by the holders of the Atlas Shares should first be treated as a taxable dividend to the extent of Atlas’s current and accumulated earnings and profits that are allocated to such shares. To the extent the Distribution exceeds Atlas’s current and accumulated earnings and profits that are allocated to the Atlas Shares, but does not exceed the shareholders’ tax basis in such Atlas Shares, it should be treated as a non-taxable return of capital. This non-taxable return of capital reduces the shareholders’ tax basis in the Atlas Shares. To the extent the Distribution exceeds the shareholders’ tax basis in the Atlas Shares, it should be treated as a taxable capital gain.

THE DISTRIBUTION TO U.S. SHAREHOLDERS
Under current law, subject to holding period requirements and certain other limitations, dividends received with respect to publicly traded shares by a shareholder that is a U.S. citizen or resident individual, trust or estate (a Non-Corporate U.S. Shareholder), generally will be treated as “qualified dividend income” that is taxable to such Non-Corporate U.S. Shareholder at preferential capital gain tax rates. The portion of the Distribution treated as a dividend is considered “qualified dividend income” if the following conditions are satisfied:

(1) The Atlas Shares are readily tradable on an established securities market in the United States (such as the New York Stock Exchange on which such shares are traded);

(2) Atlas is not a passive foreign investment company (PFIC) for the taxable year during which the dividend is paid or the immediately preceding taxable year. A PFIC, in general, is a corporation that earns 75% or more of its income from a passive source or uses at least 50% of its assets to earn passive income. We do not believe that Atlas is or has been a PFIC;

(3) The Non-Corporate U.S. Shareholder holds the Atlas Shares for more than 60 days during the 121-day period that begins 60 days before the ex-dividend date. The ex-dividend date is the first date following the declaration of a dividend on which the buyer of the Atlas Shares is not entitled to receive the next dividend payment. Instead, the seller will get the dividend; and

(4) The Non-Corporate U.S. Shareholder is not under an obligation to make related payments with respect to positions in substantially similar or related property.

Qualified dividend income is taxed at a preferential maximum rate of 0%, 15%, or 20%, depending on the income level of the taxpayer. However, if the above listed conditions are not satisfied or if the U.S. shareholder is a U.S. corporation, then that part of the Distribution characterized as dividends should be treated as ordinary income taxable at the regular graduated income tax rates.

Special rules may apply to any “extraordinary dividend” paid by us. Generally, an extraordinary dividend is a dividend with respect to a share of stock that is equal to or in excess of 10% of a common shareholder’s, or 5% of a preferred shareholder’s, adjusted tax basis (or fair market value upon the shareholder’s election) in such share. In addition, extraordinary dividends include dividends received within a one year period that, in the aggregate, equal or exceed 20% of a shareholder’s adjusted tax basis (or fair market value). If we pay an extraordinary dividend on our shares that is treated as qualified dividend income, then any loss recognized by a Non-Corporate U.S. Shareholder from the sale or exchange of such shares will be treated as long-term capital loss to the extent of the amount of such dividend.

NON-CORPORATE U.S. SHAREHOLDER EXAMPLE:
For this simplified example, assume a Non-Corporate U.S. Shareholder (i) purchased one common share of Atlas Corp. for $21.00 at the time of Atlas Corp’s initial public offering, (ii) held that common share as a capital asset (meaning generally, that the share was held for investment purposes) through the date of the distribution on November 10, 2006, and (iii) was not under an obligation to make related payments with respect to positions in substantially similar or related property.

In 2006, the Non-Corporate U.S. Shareholder received a total of $1.70 in distributions from Atlas Corp., of which $0.27 is treated as a dividend, and the remaining $1.43 is treated other than as a dividend. Depending on the Non-Corporate U.S. Shareholder’s circumstances, the $0.27 of the distribution treated as a dividend may be considered “qualified dividend income” which is generally subject to a maximum tax rate of 15%, provided all of the conditions outlined above are met. The remaining $1.43 of the distribution treated other than as a dividend would be considered a non-taxable return of capital because the distributions received to date by the shareholder have not exhausted his tax basis of $21.00 in his common share. This non-taxable return of capital will reduce the shareholder’s tax basis in his common share to $19.57 ($21.00 original tax basis less $1.43 return of capital).  The $1.43 of the distribution treated other than as a dividend is not taxed until the shareholder’s basis in the share is fully recovered.

U.S. INTERNAL REVENUE CODE SECTION 6045B REPORTING
Effective January 1, 2011, issuers of corporate stock must begin reporting corporate actions that affect the stock basis, including but not limited to mergers, stock splits, stock dividends, recapitalizations and distributions in excess of cumulative earnings and profits. The following information is intended to meet the requirements of public disclosure pursuant to Treasury Regulation Section 1.6045B-1(a)(3) and (b)(4) for Atlas Corp.

CANADIAN SHAREHOLDERS
The foregoing chart and information applies only to U.S. resident recipients. Canadian resident shareholders will be required to include the full amount of the Distribution into taxable income for Canadian tax purposes. As Atlas Corp. is not a resident of Canada, the dividend tax credit will not be available in respect of these dividends. These comments are for general purposes only. Canadian shareholders should contact their own tax advisors to determine their specific Canadian tax consequences.

NON-U.S. SHAREHOLDERS
Non-U.S. shareholders should contact their own tax advisors to determine the appropriate tax treatment with respect to the distributions they receive.

DISCLAIMER
This chart and related comments are intended as general information only. This information was not written or intended to be used, and it cannot be used, by any person as a basis for avoiding federal tax penalties that may be imposed on that person. Shareholders should consult their own tax advisors with respect to the specific tax consequences to them. Atlas Corp. makes no warranty either expressed or implied regarding any tax issues of its shareholders. The above information has been provided by the Atlas Corp. to its transfer agent.

THIS SUMMARY IS BASED ON THE TAX LAWS OF THE UNITED STATES, INCLUDING THE CODE, TREASURY REGULATIONS (FINAL, TEMPORARY AND PROPOSED), ADMINISTRATIVE RULINGS AND PRACTICE, AND JUDICIAL DECISIONS IN EFFECT AND THE TAX LAWS OF CANADA (INCLUDING THE INCOME TAX ACT (CANADA), THE REGULATIONS THEREUNDER, ADMINISTRATIVE RULINGS AND PRACTICE AND JUDICIAL DECISIONS IN EFFECT) AS OF THE DATE OF THIS INFORMATION STATEMENT, ALL OF WHICH ARE SUBJECT TO CHANGE, POSSIBLY WITH RETROACTIVE EFFECT. SHAREHOLDERS SHOULD CONSULT THEIR OWN TAX ADVISORS REGARDING THE PARTICULAR TAX CONSEQUENCES OF THE DISTRIBUTION, INCLUDING, BUT NOT LIMITED TO, THE APPLICATION AND EFFECT OF ANY STATE, LOCAL FOREIGN AND OTHER TAX LAWS, AS WELL AS THE CONSEQUENCES OF ANY RECENT, PENDING OR PROPOSED CHANGES IN THE APPLICABLE LAWS.

In connection with Atlas' merger transaction (announced at: https://ir.atlascorporation.com/2023-03-28-Atlas-and-Poseidon-Announce-Completion-of-Acquisition-by-Poseidon-Acquisition-Corp), Atlas common shares were suspended from trading from the New York Stock Exchange ("NYSE") on March 28, 2023, and were delisted from the NYSE on April 10, 2023.