Section 5. Required Statements of the Corporation

The Corporation must provide the following statements required by section 3.06(2)(c)(ii)(E)( 1 ) through ( 3 ) of Rev. Proc. 2022-19.

1. The Corporation acknowledges that the relief provided by section 3.06 of Rev. Proc. 2022-19 is limited solely to each non‑identical governing provision described in this Corporate Governing Provision Statement.

2. The Corporation acknowledges that the relief provided by section 3.06 of Rev. Proc. 2022-19 is based solely on the information, representations, and other statements provided by the Corporation pursuant to section 3.06 of Rev. Proc. 2022-19, each of which is subject to verification during IRS examination.

3. During the period between the date on which the non-identical governing provision became effective and the date on which all of the procedures described in section 3.06 of Rev. Proc. 2022-19 are completed, each applicable shareholder has reported their income on all affected returns consistent with the S corporation election for the taxable year the non-identical governing provision became effective and for all subsequent years for which each applicable shareholder owned shares of the Corporation.