Tax Information

Important Tax Information for Orla Shareholders

The income tax consequences of this transaction will depend on your country of tax residence and your individual circumstances. Canadian resident shareholders should note that, while the exchange of their shares is generally treated as a taxable disposition for Canadian income tax purposes, eligible shareholders may be able to elect under section 85 of the Income Tax Act (Canada) to defer all or a portion of the resulting taxable gain. This election is optional but is subject to strict eligibility requirements, filing procedures and deadlines. If you are a Canadian resident shareholder and wish to determine whether a section 85 election is appropriate for your circumstances, you should carefully review this Tax Instruction Letter and consult your own tax advisor. If you decide to make the election, you must complete and submit the required Tax Election Form in accordance with the instructions provided. Failure to properly complete the election or meet the applicable filing deadline may result in the loss of the available tax deferral.

U.S. resident shareholders should also carefully review the Tax Instruction Letter and the tax discussion contained in the management information circular, which summarizes the intended U.S. federal income tax treatment of the transaction and other important tax considerations. The U.S. federal income tax consequences of the transaction are complex and will depend on each shareholder’s particular circumstances. All shareholders are strongly encouraged to consult their own tax advisors regarding the tax consequences of the transaction applicable to them.

PFIC Statement

Equinox Gold was not a passive foreign investment company (PFIC) in 2025, 2024, 2023, 2022, 2021 or 2020.

Tax Information for Orla, Calibre, Premier, Leagold, NewCastle, Luna Gold and Anfield Shareholders

On July 31, 2026, Equinox Gold Corp. combined with Orla Mining Corp. (the “Orla Arrangement”), issuing 1.0 Equinox Gold common shares and $0.0001 in cash for each Orla share held. For former U.S. shareholders of Orla, the Company will create an IRS Form 8937 to provide general U.S. tax information on the combination with Orla. The form will be posted here as soon as possible.

In June 2025, Equinox Gold Corp. combined with Calibre Mining Corp. (the “Calibre Arrangement”), issuing 0.35 Equinox Gold common shares for each Calibre share held. For former U.S. shareholders of Calibre, we have completed IRS Form 8937 to provide general U.S. tax information relating to closing of the Calibre Arrangement.

In April 2021, Equinox Gold Corp. combined with Premier Gold Mines Limited (the “Premier Arrangement”), issuing 0.1967 Equinox Gold common shares for each Premier share held. For former U.S. shareholders of Premier, we have completed IRS Form 8937 to provide general U.S. tax information relating to closing of the Premier Arrangement.

In March 2020, Equinox Gold Corp. combined with Leagold Mining Corporation (the “Leagold Arrangement”), issuing 0.331 Equinox Gold common shares for each Leagold share held. For former U.S. shareholders of Leagold, we have completed IRS Form 8937 to provide general U.S. tax information in relation to the Leagold Arrangement.

In December 2017, Equinox Gold Corp. undertook an arrangement to combine with NewCastle Gold Ltd. and Anfield Gold Corp. (the “Equinox Gold Arrangement”), issuing 0.873 Equinox Gold common shares for each NewCastle Gold share held and 0.407 Equinox Gold common shares for each Anfield Gold share held. For former U.S. shareholders of NewCastle Gold and Anfield Gold, we have completed IRS Form 8937 to provide general U.S. tax information in relation to the Equinox Gold Arrangement.

In March 2017, Trek Mining Inc. combined with Luna Gold Corp., issuing 1.105 Trek common shares for each Luna Gold share held (the “Luna Gold Arrangement”). For former U.S. shareholders of Luna Gold, we have completed IRS Form 8937 to provide general U.S. tax information relating to the Luna Gold Arrangement.

The information contained herein and in the IRS Form 8937 attachments does not constitute tax, accounting or legal advice and does not purport to be complete or to describe the consequences that may apply to particular categories of shareholders. Equinox Gold does not provide tax, accounting or legal advice. Any tax statements contained herein and in the attachment were not intended or written to be used, and cannot be used, for the purpose of avoiding penalties imposed under the Internal Revenue Code. You are urged to consult your own tax advisor regarding the particular consequences of the distribution to you, including the applicability and effect of all U.S. federal, state, local and foreign tax laws.