Purple will make a determination as to whether the redemption of the PRPLS is taxable following the end of its taxable year. This determination depends upon whether Purple has current or accumulated earnings and profits, and will not be known until after the end of the taxable year. However, Purple does not expect to have such earnings and profits, in which case the redemption should generally be treated for federal income tax purposes as a tax-free return of shareholder basis (if any) in the PRPLS and thereafter as capital gain.