Centrais Elétricas Brasileiras S.A. – Eletrobrás Form 6-K Filing

This Form 6-K filing from Centrais Elétricas Brasileiras S.A. – Eletrobrás details a series of transactions, including the creation of new Class C preferred shares and ADSs, and a Preferred B1 ADS Exchange. The filing outlines the ticker symbols for these new securities (B3: AXIA7, NYSE: AXIA PRC) and clarifies that existing security trading codes will remain unchanged. A significant portion of the document is dedicated to explaining the potential U.S. federal income tax consequences for U.S. Holders of the company's ADSs, covering aspects like the Preferred B1 ADS Exchange, distributions, redemptions, and auctions. It also addresses the Passive Foreign Investment Company (PFIC) rules and backup withholding and information reporting requirements. The company states it does not expect to be a PFIC but advises U.S. Holders to consult their tax advisors due to the complexity and potential changes in tax laws and the factual nature of PFIC determinations. The filing emphasizes that these transactions and their tax implications are subject to shareholder approval and further clarification on implementation logistics will be provided.