Pengrowth believes that it is characterized as a SIFT trust and, as a result, will be subject to Bill C-52 commencing on January 1, 2011.

• Tax applied on distributions paid at the trust level has been revised to 25 percent, in line with corporate rates and will begin to take effect starting in 2011.

•  Tax deferred conversion to corporate structure is available until 2013.

• Pengrowth's tax pools of approximately $3.0 billion will shelter impacts of SIFT tax post 2011.

  - Without the tax pools distributions would have been reduced by 25 percent starting in 2011 however when including the tax pools Pengrowth has the ability to shield a portion of the tax for a couple of years beyond 2011. When including the tax pools the effective tax rate could be reduced from 25 percent to 15 -18 percent.

• Pengrowth can continue to have the benefit of its tax structure through December 31, 2010 and is currently reviewing all the opportunities available and working with legal and tax advisors to find the most beneficial post 2011 structure for unitholders