Providing Memorandum Revenue Wealth Administration

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Income earned derived from foreign sources could also be topic to overseas withholding taxes which, to the extent permitted by the Tax Act, could also be claimed as a deduction or credit by Fund Unitholders. To the extent that distributions to Fund Unitholders exceed the online income and web realized capital features of the Fund for the year, such excess distributions won't be taxable within the palms of the Fund Unitholder but will reduce the adjusted price base to the Fund Unitholder of such Fund Unitholder’s Fund Units. If the adjusted cost base to the Fund Unitholder of such Fund Unitholder’s Fund Units becomes negative, the quantity by which it is unfavorable is a direct capital achieve to the Fund Unitholder, and the adjusted value base of the Fund Units resets at zero. This summary isn't exhaustive of all attainable Canadian federal revenue tax issues and does not cope with other federal, provincial or overseas revenue tax legislation or issues. This abstract does not address the deductibility of interest on any funds borrowed by a Fund Unitholder to purchase Fund Units. This summary is of a common nature only and isn't intended to constitute authorized or tax recommendation to any particular Investor.

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