On its acquisition of Rupert Resources, Agnico Eagle issued contingent value rights that now trade on the TSX

On June 16, 2026, Agnico Eagle acquired all the shares of Rupert Resources in consideration for the issuance of Agnico Eagle common shares and of contingent value rights (CVRs).

Each CVR entitles its holder to the following payments if the specified conditions are met within 10 years of the effective date of the Plan Of Arrangement:

• $1.00 upon the public announcement by Agnico Eagle that the mineral reserves on the Rupert property are not less than 5 million ounces of gold (the current published reserves were 3.5 million);
• a further $1.00 upon Agnico Eagle publicly announcing that such property has reached commercial production and that the reserves, together with previously produced ounces, are not less than 7.5 million ounces; and
• a further $1.00 upon an announced reaching of 10 million.

Taxable resident shareholders were permitted to file a joint election under s. 85(1) or (2) with Agnico Eagle provided they submit a duly completed and signed election form within 120 days of the Arrangement. Agnico Eagle transferred all of its Rupert shares (including its previous 13.9% stake) to a new BC sub, which then amalgamated with Rupert.

The cost of a CVR for Canadian and U.S. tax purposes is considered to be equal to its FMV at the time of acquisition. The Canadian tax disclosure treats each milestone payment receipt as giving rise to a part disposition or disposition of CVRs for capital gains purposes; whereas the most likely treatment suggested for U.S. tax purposes is to treat payments on a CVR (except to the extent treated as imputed interest) as a return of the U.S. holder's adjusted cost base in such CVR and thereafter as gain. The U.S. tax disclosure indicates that Agnico Eagle intended to treat the FMV of a CVR on the effective date of the Arrangement as $0.65.

With a view to the CVRs being qualified investments to registered plans, Agnico Eagle agreed to use commercially reasonable efforts to obtain conditional approval for the listing of the CVRs on the TSX by Arrangement implementation. This occurred. The listing was approved on a discretionary basis under the TSX Sandbox (for the accommodation of novel securities that do not meet all the listing requirements). See Ghaith Sibai, “First-Ever Listing of Contingent Value Rights on the TSX,” Davies Insights, 7 July 2026 The most recent closing price for AEM.CV was $0.59.

Neal Armstrong. Summary of Circular of Rupert Resources Ltd. (the "Company”) respecting its proposed Plan of Arrangement with Agnico Eagle Mines Limited (“Agnico Eagle”) under Mergers – Mergers & Acquisitions – Mergers – Shares for CVRs and Shares/ Cash.