Contract analysis

I. SCOPE OF IDR NO. 40 IDR No. 40 requests that PPC produce all Forms 5471 (Information Return of U.S. Persons with Respect to Certain Foreign Corporations) filed by PPC with its consolidated federal income tax returns (Forms 1120) for the tax years ended December 31, 2017, December 31, 2018, December 31, 2019, and December 31, 2020 (collectively, the "Tax Years Under Examination" or "TY 2017," "TY 2018," "TY 2019,"

II. DOCUMENTS PRODUCED In response to IDR No. 40, PPC produces the documents described below. All documents produced herewith are organized by entity and tax year, as further detailed in the Production Index enclosed as Enclosure 4. A. Forms 5471 for Penterra Biopharma International DAC (PBI) PPC produces herewith complete copies of the Forms 5471 filed by PPC with respect to PBI for each of the four Tax Years Under

III. NOTES AND QUALIFICATIONS PPC provides the following notes and qualifications with respect to this production: Completeness. All Forms 5471, Forms 8858, and related international informational returns and schedules produced herewith are true and complete copies of the returns as originally filed with PPC's consolidated federal income tax returns (Forms 1120) for TY 2017, TY 2018, TY 2019, and TY 2020. PPC has ver

IV. AVAILABILITY FOR QUESTIONS C&H and PPC remain fully available to discuss any questions that may arise from the documents produced in response to IDR No. 40. Should Revenue Agent Dunleavy or Supervisory Revenue Agent Gerald Meskill require any further clarification regarding the Forms 5471, the related international informational returns, or the intercompany transactions reflected therein, we would be pleased to a