RFA Financial became a public company in February 2026, pursuant to a plan of arrangement between Artis Real Estate Investment Trust & RFA Capital.

ELIGIBLE DIVIDEND DESIGNATION

For the purposes of the Income Tax Act (Canada) and any similar provincial or territorial tax legislation, all dividends (including deemed dividends) paid by RFA to Canadian residents on our common and preferred shares after February 2, 2026, are designated as “eligible dividends” unless otherwise indicated in respect of dividends paid after this notice.

The Section 85 Election Questionnaire for the Section 85 Rollover in respect of the Plan of Arrangement is now available. Detailed tax instructions can be found here: Tax Instruction Letter.

The exchange of Artis Common Units, Series E Preferred Units and Series I Preferred Units (collectively, “Artis Trust Units”) for RFA Financial Common Shares, Series E Preferred Shares and Series I Preferred Shares (collectively, “RFA Financial Shares”), respectively are generally considered a taxable event for Canadian income tax purposes. However, it is possible to defer some or all of any tax resulting from the Artis Trust Unit for RFA Financial Share exchange by filing, jointly with RFA Financial, a Section 85 Tax Election Form and submitting these Forms with the Canada Revenue Agency and Revenu Quebec (where applicable).

Eligible Unitholders (as defined in the Plan of Arrangement) will use the following link located here, to provide RFA Financial with the relevant information to prepare the applicable Section 85 Tax Election Forms and the Tax Instruction Letter which will provide unitholders with the relevant guidance on answering the questions in the Section 85 Election Questionnaire and filing the Forms with the appropriate tax authorities. However, before filing these Forms with the applicable tax authorities, we recommend reviewing them with your tax advisors to ensure they are complete and accurate.

The deadline for submission of the information through the Section 85 Election Questionnaire is May 2, 2026. All Eligible Unitholders who wish to make a Section 85 Election should give their immediate attention to this matter, and should consult their tax advisors without delay. If the information is submitted by the date listed above, RFA Financial will email 2 signed copies of each applicable Section 85 Tax Election Form to the email listed in the Section 85 Election Questionnaire within 60 days after the date in which the information is submitted.

Any Eligible Unitholder who does not provide all accurate information to RFA Financial in respect of the Section 85 Election Rollover cannot be assured of benefiting from the rollover provisions of the Income Tax Act (Canada) (or the corresponding provisions of any applicable provincial tax legislation).

Some Eligible Unitholders may not be required to file a Section 85 Tax Election Form with the appropriate tax authorities. If you meet any of the following criteria you are not required to file a Section 85 Tax Election Form:

• You are a non-resident of Canada (unless certain exceptions apply).
• You held all of your Artis Trust Units in an RRSP, RRIF, RESP, RPP or other tax-exempt plan or other entity exempt from Tax under Section 149 of the Income Tax Act (Canada).
• You realized a tax loss as a result of the disposition of your Artis Trust Units.

It is RFA Financial’s and Artis’s understanding that there are no Artis Trust Unitholders that are non-residents of Canada who at any time within the last 60 months before the Effective Date (February 1, 2026) owned more than 25% of the all the issued units of Artis (including units owned by persons not dealing at arm’s length with the non-resident unitholder as determined under Canadian tax law) (the “25% test”). If a non-resident unitholder believes they in fact met the 25% test at any time in the past 60 months prior to the Effective Date, please contact [email protected].