Common use of CERTAIN CANADIAN FEDERAL INCOME TAX CONSIDERATIONS Clause in Contracts

CERTAIN CANADIAN FEDERAL INCOME TAX CONSIDERATIONS. The following summary describes the principal Canadian federal income tax considerations under the Tax Act of the Arrangement generally applicable to a beneficial owner of Romarco Shares who, at all relevant times, for purposes of the Tax Act: (i) deals at arm’s length with Romarco and OceanaGold; (ii) is not affiliated with Romarco or OceanaGold; and (iii) holds its Romarco Shares, and will hold the OceanaGold Shares received upon the Arrangement, as capital property (a “Holder”). This summary only addresses Holders. Romarco Shares will generally be considered to be capital property to a Holder unless such Romarco Shares are held by the Holder in the course of carrying on a business of buying and selling securities or were acquired in one or more transactions considered to be an adventure or concern in the nature of trade. This summary is not applicable to a Holder: (i) that is a “specified financial institution” for the purposes of the Tax Act; (ii) that is a “financial institution” for the purposes of the mark-to-market rules in the Tax Act; (iii) an interest in which is a “tax shelter investment” for the purposes of the Tax Act; (iv) who makes or has made a functional currency reporting election for the purposes of the Tax Act; (v) that is a foreign affiliate, as defined in the Tax Act, of a taxpayer resident in Canada; or (vi) that has entered into or will enter into a “derivative forward agreement”, as defined in the Tax Act, in respect of the Romarco Shares or OceanaGold Shares. In addition, this summary does not address the tax considerations to Romarco Optionholders. Such Romarco Shareholders and Romarco Optionholders should consult their own tax advisors. Additional considerations, not discussed herein, may be applicable to a Holder that is a corporation resident in Canada and is, or becomes, controlled by a non-resident corporation for the purposes of the “foreign affiliate dumping” rules in section 212.3 of the Tax Act. Such Holders should consult their own tax advisors. This summary is based on the current provisions of the Tax Act, and on counsels’ understanding of the current administrative policies and assessing practices of the CRA published in writing prior to the date hereof. This summary takes into account all specific proposals to amend the Tax Act publicly announced by or on behalf of the Minister of Finance (Canada) prior to the date hereof (the “Proposed Amendments”) and assumes that all Proposed Amendments will be enacted in the form proposed. However, no assurances can be given that the Proposed Amendments will be enacted as proposed, or at all. This summary does not otherwise take into account or anticipate any changes in law or administrative policy or assessing practice whether by legislative, regulatory, administrative or judicial action nor does it take into account tax legislation or considerations of any province, territory or foreign jurisdiction, which may differ from those discussed herein. This summary is of a general nature only and is not, and is not intended to be, legal or tax advice to any particular Romarco Shareholder. This summary is not exhaustive of all Canadian federal Income tax considerations. Accordingly, Romarco Shareholders should consult their own tax advisors having regard to their own particular circumstances. This portion of the summary is generally applicable to a Holder who, at all relevant times, for purposes of the application of the Tax Act: (i) is, or is deemed to be, resident in Canada; and (ii) is not exempt from tax under Part I of the Tax Act (a “Resident Holder”). Certain Resident Holders whose Romarco Shares or OceanaGold Shares might not otherwise qualify as capital property may be entitled to have such shares, and all other “Canadian securities” (as defined in the Tax Act) owned by them in the taxation year and any subsequent taxation year, deemed to be capital property by making an irrevocable election in accordance with subsection 39(4) of the Tax Act. Resident Holders considering making such an election should consult their own tax advisors for advice as to whether the election is available or advisable in their own particular circumstances.

CERTAIN CANADIAN FEDERAL INCOME TAX CONSIDERATIONS. The following is a summary describes of the principal Canadian federal income tax considerations generally applicable under the Income Tax Act of (Canada) and the Arrangement generally applicable regulations thereunder (collectively, the “Tax Act”) related to the transactions contemplated in this notice (assuming that the Closing occurs) to a beneficial owner of Romarco Shares Debentureholder who, at all relevant times, for purposes of the Tax Act: Act and at all relevant times, (i) deals at arm’s length with Romarco and OceanaGold; (ii) is not affiliated with Romarco or OceanaGold; and the Company, (ii) beneficially owns their Convertible Debentures including all entitlements to payments thereunder, (iii) holds its Romarco Shareshas not entered and will not enter into, in respect of their Convertible Debentures, a “synthetic disposition arrangement” or a “derivative forward agreement” (each as defined in the Tax Act), and will hold (iv) holds the OceanaGold Shares received upon the Arrangement, Convertible Debentures as capital property (a “Holder”). This summary only addresses Holders. Romarco Shares Generally, the Convertible Debentures will generally be considered to be capital property to a Holder unless such Romarco Shares are held by provided that the Holder does not acquire or hold the Convertible Debentures in the course of carrying on a business or as part of buying and selling securities or were acquired in one or more transactions considered to be an adventure or concern in the nature of trade. This summary is not applicable to a Holder: (i) that is a “specified financial institution” for the purposes of the Tax Act; (ii) that is a “financial institution” for the purposes of the mark-to-market rules in the Tax Act; (iii) an interest in which is a “tax shelter investment” for the purposes of the Tax Act; (iv) who makes or has made a functional currency reporting election for the purposes of the Tax Act; (v) that is a foreign affiliate, as defined in the Tax Act, of a taxpayer resident in Canada; or (vi) that has entered into or will enter into a “derivative forward agreement”, as defined in the Tax Act, in respect of the Romarco Shares or OceanaGold Shares. In addition, this summary does not address the tax considerations to Romarco Optionholders. Such Romarco Shareholders and Romarco Optionholders should consult their own tax advisors. Additional considerations, not discussed herein, may be applicable to a Holder that is a corporation resident in Canada and is, or becomes, controlled by a non-resident corporation for the purposes of the “foreign affiliate dumping” rules in section 212.3 of the Tax Act. Such Holders should consult their own tax advisors. This summary is based on the current provisions of the Tax Act, Act and on counsels’ an understanding of the current administrative policies and assessing practices of the CRA Canada Revenue Agency (the “CRA”) published in writing prior to the date hereof. This summary takes into account all specific proposals to amend the Tax Act publicly announced by or on behalf of the Minister of Finance (Canada) prior to the date hereof (the “Proposed AmendmentsTax Proposals”) and assumes that all Proposed Amendments Tax Proposals will be enacted in the form proposed. However, no assurances can be given that the Proposed Amendments Tax Proposals will be enacted as proposed, or at all. This summary does not otherwise take into account or anticipate any changes in law or administrative policy or assessing practice practice, whether by legislative, regulatory, administrative or judicial action action, nor does it take into account tax legislation or considerations of any province, territory or foreign jurisdiction, which may differ from those discussed herein. This The discussion in this summary is limited to the principal Canadian federal income tax considerations arising to a Holder solely as a result of a general nature only (i) the conversion of Convertible Debentures during the Make Whole Conversion Period prior to the Conversion Deadline (the “Pre-Closing Conversion”), (ii) the defeasance of the Convertible Debentures and is not, and is not intended to be, legal or tax advice to any particular Romarco Shareholder(iii) the conversion of Convertible Debentures during the Make Whole Conversion Period after the Conversion Deadline (the “Post-Closing Conversion”). This summary is does not exhaustive of all describe the Canadian federal Income income tax considerations. Accordingly, Romarco Shareholders should consult their own tax advisors having regard to their own particular circumstances. This portion considerations of the summary is generally applicable Arrangement to a Holder whothat acquires Common Shares pursuant to the conversion of their Convertible Debentures (including as a result of the Pre-Closing Conversion). For a discussion of the Canadian federal income tax consequences of the Arrangement to holders of Common Shares, Holders should review the Company’s management information circular and proxy statement dated March 2, 2021 in respect of the special meetings of the holders of the Common Shares of the Company and the Preferred Shares of Atlantic Power Preferred Equity Ltd. to approve the Arrangement, a copy of which is available on SEDAR under the Company’s profile at all relevant timesxxx.xxxxx.xxx. Generally, for purposes of the application Tax Act, all amounts relating to the acquisition, holding or disposition of Convertible Debentures and Common Shares acquired on the exercise of Convertible Debentures must be determined in Canadian dollars. Any such amount that is expressed or denominated in a currency other than Canadian dollars must be converted into Canadian dollars using the relevant exchange rate determined in accordance with the Tax Act: (i) is, or is deemed to be, resident in Canada; and (ii) is not exempt from tax under Part I of the Tax Act (a “Resident Holder”). Certain Resident Holders whose Romarco Shares or OceanaGold Shares might not otherwise qualify as capital property may be entitled to have such shares, and all other “Canadian securities” (as defined in the Tax Act) owned by them in the taxation year and any subsequent taxation year, deemed to be capital property by making an irrevocable election in accordance with subsection 39(4) of the Tax Act. Resident Holders considering making such an election should consult their own tax advisors for advice as to whether the election is available or advisable in their own particular circumstances.

CERTAIN CANADIAN FEDERAL INCOME TAX CONSIDERATIONS. The following is, as of the date of this Prospectus Supplement, a summary describes of the principal Canadian federal income tax considerations under theIncome Tax Act (Canada) (“Tax Act”) and the regulations thereunder (the “Regulations”) generally applicable to an investor who acquires as beneficial owner Common Shares pursuant to the Offering and who, for the purposes of the Tax Act and the Regulations and at all relevant times deals at arm’s length with the Corporation and the Agent, is not affiliated with the Corporation or the Agent, is not exempt from tax under Part I of the Arrangement Tax Act, and who acquires and holds the Common Shares, as capital property (a “ Holder”). Generally, the Common Shares will be considered to be capital property to a Holder provided that the Holder does not hold the Common Shares in the course of carrying on a business as part of an adventure or concern in the nature of trade. This summary is generally applicable to a beneficial owner of Romarco Shares Holder who, at all relevant times, for purposes of the Tax Act: (i) deals at arm’s length with Romarco is not, and OceanaGold; (ii) is not affiliated with Romarco or OceanaGold; and (iii) holds its Romarco Sharesdeemed to be, and will hold the OceanaGold Shares received upon the Arrangement, as capital property (a “Holder”). This summary only addresses Holders. Romarco Shares will generally be considered to be capital property to a Holder unless such Romarco Shares are held by the Holder resident in the course of carrying on a business of buying and selling securities or were acquired in one or more transactions considered to be an adventure or concern in the nature of trade. This summary is not applicable to a Holder: (i) that is a “specified financial institution” Canada for the purposes of the Tax ActAct or any applicable income tax treaty or convention; and (ii) that does not and will not use or hold, and is not and will not be deemed to hold, the Common Shares in connection with carrying on a business in Canada (a “financial institution” for the purposes of the markNon-to-market rules in the Tax Act; (iii) an interest in Resident Holder”). Special rules, which is a “tax shelter investment” for the purposes of the Tax Act; (iv) who makes or has made a functional currency reporting election for the purposes of the Tax Act; (v) that is a foreign affiliate, as defined in the Tax Act, of a taxpayer resident in Canada; or (vi) that has entered into or will enter into a “derivative forward agreement”, as defined in the Tax Act, in respect of the Romarco Shares or OceanaGold Shares. In addition, this summary does not address the tax considerations to Romarco Optionholders. Such Romarco Shareholders and Romarco Optionholders should consult their own tax advisors. Additional considerations, are not discussed hereinin this summary, may be applicable apply to a Holder certain holders that is a corporation resident are insurers carrying on an insurance business in Canada and is, or becomes, controlled by a non-resident corporation for the purposes of the “foreign affiliate dumping” rules in section 212.3 of the Tax Actelsewhere. Such Holders should consult their own tax advisorsadvisors with respect to an investment in Common Shares. This summary is based on upon the current provisions of the Tax Act, Act and on counsels’ the Regulations in force as of the date hereof and counsel’s understanding of the current administrative policies and assessing practices of the CRA Canada Revenue Agency (the “ CRA”) published in writing by the CRA prior to the date hereof. This summary takes into account all specific proposals to amend the Tax Act and the Regulations publicly announced by or on behalf of the Minister of Finance (Canada) prior to the date hereof (the “Proposed AmendmentsTax Proposals”) and assumes that all Proposed Amendments the Tax Proposals will be enacted in the form proposed. However, although no assurances assurance can be given that the Proposed Amendments Tax Proposals will be enacted as proposed, in their current form or at all. This Other than the Tax Proposals, this summary does not otherwise take into account or anticipate any changes in law or administrative policy or assessing practice law, whether by legislative, regulatorygovernmental, administrative or judicial action decision or action, nor does it take into account tax legislation or considerations of consider any provinceprovincial, territory territorial or foreign jurisdictionincome tax considerations, which considerations may differ significantly from those the Canadian federal income tax considerations discussed hereinin this summary. This summary also does not take into account any change in the administrative policies or assessing practices of the CRA. For purposes of the Tax Act, all amounts relating to the acquisition, holding or disposition of the Common Shares (including dividends, adjusted cost base and proceeds of disposition) must, to the extent such amounts are not in Canadian dollars, be converted into Canadian dollars based on an exchange rate determined in accordance with the Tax Act. Dividends paid or credited or deemed to be paid or credited on the Common Shares to a Non-Resident Holder by the Corporation are subject to Canadian withholding tax at the rate of 25% on the gross amount of the dividend, unless such rate is reduced by the terms of an applicable tax treaty. For example, under the Canada-United States Tax Convention (1980), as amended (the “Treaty”), the rate of withholding tax on dividends paid or credited to a general nature only Non-Resident Holder who is a beneficial owner of dividends and who is not, a resident of the United States for purposes of the Treaty and who is not intended entitled to be, legal or tax advice the benefits of the Treaty (a “US Holder”) is generally limited to any particular Romarco Shareholder15% of the gross amount of the dividend. This summary is not exhaustive of all Canadian federal Income tax considerations. Accordingly, Romarco Shareholders should Non-Resident Holders are urged to consult their own tax advisors having regard to determine their own particular circumstances. This portion of the summary is generally entitlement to relief under an applicable to a Holder who, at all relevant times, for purposes of the application of the Tax Act: (i) is, or is deemed to be, resident in Canada; and (ii) is not exempt from income tax under Part I of the Tax Act (a “Resident Holder”). Certain Resident Holders whose Romarco Shares or OceanaGold Shares might not otherwise qualify as capital property may be entitled to have such shares, and all other “Canadian securities” (as defined in the Tax Act) owned by them in the taxation year and any subsequent taxation year, deemed to be capital property by making an irrevocable election in accordance with subsection 39(4) of the Tax Act. Resident Holders considering making such an election should consult their own tax advisors for advice as to whether the election is available or advisable in their own particular circumstancestreaty.

CERTAIN CANADIAN FEDERAL INCOME TAX CONSIDERATIONS. The following In the opinion of Xxxxxx Blaikie LLP, Canadian counsel to us and Blake, Xxxxxxx & Xxxxxxx LLP, Canadian counsel to the placement agents, (collectively, “Counsel”) the following, as of the date hereof, is a summary describes of the principal Canadian federal income tax considerations under the Tax Act of the Arrangement generally applicable to the acquisition, holding and disposition of unit shares and warrants by a beneficial owner of Romarco Shares holder who acquires units pursuant to the Offering and who, at all relevant times, for purposes of the Income Tax Act (Canada) (the “Tax Act: (i”) and at all relevant times deals at arm’s length with Romarco and OceanaGold; (ii) is not affiliated with Romarco YM or OceanaGold; the placement agents and holds common shares of YM (iii“Common Shares”) holds its Romarco Shares, and will hold the OceanaGold warrants as capital property. The Common Shares received upon the Arrangementor warrants, as capital property (a “Holder”). This summary only addresses Holders. Romarco Shares the case may be, will generally be considered to be constitute capital property to a Holder holder thereof unless such Romarco the holder holds the Common Shares are held by or warrants, as the Holder case may be, in the course of carrying on a business of buying and selling securities or were acquired acquires the Common Shares or warrants in one a transaction or more transactions considered to be an adventure or concern in the nature of trade. Certain holders resident in Canada for purposes of the Tax Act who might not otherwise be considered to hold their Common Shares as capital property may, in certain circumstances, be entitled to make an irrevocable election under subsection 39(4) of the Tax Act to have such Common Shares and every other “Canadian security” (as defined in the Tax Act) owned by such holder in the taxation year of the election and in all subsequent taxation years deemed to be capital property. The election under subsection 39(4) of the Tax Act does not apply to deem the warrants to be capital property. Holders contemplating such election should consult their own tax advisers for advice as to whether an election under subsection 39(4) is available and/or advisable in their particular circumstances. This summary is not applicable to a Holderholder: (i) that is a “financial institution” (as defined in the Tax Act for purposes of the xxxx-to-market rules); (ii) that is a “specified financial institution” for the purposes of the Tax Act; (ii) that is a “financial institution” for the purposes of the mark-to-market rules as defined in the Tax Act); (iii) an interest in which is would be a “tax shelter investment” for the purposes of the Tax Act; (iv) who makes or has made a functional currency reporting election for the purposes of the Tax Act; (v) that is a foreign affiliate, as defined in the Tax Act, of ); (iv) that reports its Canadian tax results in a taxpayer resident in Canadacurrency other than Canadian currency; or (viv) that has entered into who holds or will enter into subsequently acquires Common Shares acquired on the exercise of a “derivative forward agreement”, stock option or other agreement to issue or sell Common Shares to an employee of YM or of a corporation or mutual fund trust (as defined in the Tax Act, in respect of the Romarco Shares or OceanaGold Shares. In addition, this summary ) that does not address the tax considerations to Romarco Optionholders. Such Romarco Shareholders and Romarco Optionholders should consult their own tax advisors. Additional considerations, not discussed herein, may be applicable to a Holder that is a corporation resident in Canada and is, or becomes, controlled by a non-resident corporation for the purposes of the “foreign affiliate dumping” rules in section 212.3 of the Tax Act. Such Holders should consult their own tax advisorsdeal with YM at arm’s length. This summary is based on upon the facts set out in the Base Prospectus and this Term Sheet, the current provisions of the Tax ActAct and the regulations thereunder (the “Regulations”), and on counsels’ understanding of the current administrative policies and assessing practices of the CRA published in writing prior to the date hereof. This summary takes into account all specific proposals to amend the Tax Act and the Regulations publicly announced by or on behalf of the Minister of Finance (Canada) prior to the date hereof (the “Proposed Amendments”) and assumes that all Counsel’s understanding of the current administrative policies and assessing practices of the Canada Revenue Agency (the “CRA”) which have been made publicly available prior to the date hereof. Except for the Proposed Amendments will be enacted Amendments, this summary does not take into account or anticipate any changes in law or administrative practice, nor does it take into account provincial or territorial tax laws of Canada or the form proposedtax laws of any foreign jurisdiction. However, no assurances No assurance can be given that the Proposed Amendments will be enacted as proposed, proposed (or at all. This summary does not otherwise take into account ) or anticipate any changes in law that legislative, judicial or administrative policy or assessing practice whether by legislative, regulatory, administrative or judicial action nor does it take into account tax legislation or considerations of any province, territory or foreign jurisdiction, which may differ from those discussed changes will not alter the statements made herein. This summary is of a general nature only and is not, and is not intended to be, nor should it be construed to be, legal or tax advice to any particular Romarco Shareholderholder. This summary is not exhaustive of all possible Canadian federal Income income tax considerationsconsiderations applicable to an investment in the Common Shares and warrants comprising the units. AccordinglyThe income and other tax consequences of acquiring, Romarco Shareholders should consult their own tax advisors having regard holding and disposing of Common Shares and warrants will vary according to their the status of the holder, the jurisdiction in which the holder resides or carries on business and, generally, the holder’s own particular circumstances. This portion Accordingly, each prospective holder of units should obtain independent advice regarding the summary is generally applicable to a Holder who, at all relevant times, for purposes income tax consequences of the application of the Tax Act: (i) is, or is deemed to be, resident in Canada; and (ii) is not exempt from tax under Part I of the Tax Act (a “Resident Holder”). Certain Resident Holders whose Romarco Shares or OceanaGold Shares might not otherwise qualify as capital property may be entitled to have such shares, and all other “Canadian securities” (as defined investing in the Tax Act) owned by them in Common Shares and warrants with reference to the taxation year and any subsequent taxation year, deemed to be capital property by making an irrevocable election in accordance with subsection 39(4) of the Tax Act. Resident Holders considering making such an election should consult their own tax advisors for advice as to whether the election is available or advisable in their holder’s own particular circumstances.

CERTAIN CANADIAN FEDERAL INCOME TAX CONSIDERATIONS. The In the opinion of Torys LLP, counsel to BFI, and Goodmans LLP, Canadian counsel to the underwriters, the following is a general summary describes of the principal Canadian federal income tax considerations generally applicable under the Tax Act of the Arrangement generally applicable to a beneficial owner of Romarco Shares notes (including entitlement to all payments thereunder) acquired hereunder who, at all relevant times, for the purposes of the Tax Act: (i) , deals at arm’s length with Romarco and OceanaGold; (ii) is not affiliated with Romarco or OceanaGold; BFI and (iii) holds its Romarco Shares, and will hold the OceanaGold Shares received upon the Arrangement, as capital property Company (a “Note Holder”). This summary only addresses Holders. Romarco Shares will generally be considered to be capital property to a Holder unless such Romarco Shares are held by the Holder in the course of carrying on a business of buying and selling securities or were acquired in one or more transactions considered to be an adventure or concern in the nature of trade. This summary is not applicable to a Holder: Note Holder (i) that is a “specified financial institution” for the purposes of the Tax Act; (ii) that is a “financial institution” (as defined in the Tax Act for the purposes of the markxxxx-to-market rules in the Tax Act; rules), (iiiii) an interest in which is a “tax shelter investment” for the purposes of the Tax Act; (iv) who makes or has made a functional currency reporting election for the purposes of the Tax Act; (v) that is a foreign affiliate, as defined in the Tax Act), of a taxpayer resident in Canada; or (viiii) that has entered elected to report its “Canadian tax results” in a functional currency in accordance with the provisions of the Tax Act or (iv) that enters into or will enter into a “derivative forward agreement”, ” (as defined in the Tax Act, ) in respect of the Romarco Shares or OceanaGold Shares. In addition, this summary does not address the tax considerations to Romarco Optionholdersnotes. Such Romarco Shareholders and Romarco Optionholders should consult their own tax advisors. Additional considerations, not discussed herein, may be applicable to a Holder that is a corporation resident in Canada and is, or becomes, controlled by a non-resident corporation for the purposes of the “foreign affiliate dumping” rules in section 212.3 of the Tax Act. Such Note Holders should consult their own tax advisorsadvisors having regard to their particular circumstances. This summary does not address the split income rules in Section 120.4 of the Tax Act. Note Holders should consult their own tax advisors in that regard. This summary is based on the current provisions of the Tax Act, Act and on counsels’ understanding of the current administrative policies and assessing practices of regulations thereunder (the CRA published “Regulations”) in writing prior to force at the date hereof. This summary takes into account of this prospectus supplement, all specific proposals to amend the Tax Act and the Regulations publicly announced by or on behalf of the Minister of Finance (Canada) prior to the date hereof and counsel’s understanding of the current administrative policies or assessment practices published in writing by the Canada Revenue Agency (the “Proposed AmendmentsCRA”) and assumes prior to the date hereof. There can be no assurance that all Proposed Amendments the proposed amendments will be enacted implemented in the their current form proposed. However, no assurances can be given that the Proposed Amendments will be enacted as proposed, or at all. This summary does not otherwise take into account or anticipate any changes in of law or administrative policy or assessing practice practice, whether by legislativejudicial, regulatorygovernmental or legislative decision or action or changes in the administrative policies or assessment practices of the CRA, administrative or judicial action nor does it take into account tax legislation or considerations of any province, territory or foreign jurisdiction, which may differ significantly from those discussed herein. This summary is assumes that no Affiliate of BFI or the Company will be added as a general nature only and is not, and is not intended to be, legal or tax advice to any particular Romarco ShareholderCo-Obligor under the notes. This summary is not exhaustive of all Canadian federal Income tax considerations. Accordingly, Romarco Shareholders Note Holders should consult with their own tax advisors having regard with respect to their own particular circumstances. This portion the tax consequences to them of the summary is generally applicable to addition of a Holder who, at all relevant times, for Co-Obligor under the notes. For purposes of the application of the Tax Act: (i) is, or is deemed to beall amounts, resident including interest, adjusted cost base and proceeds of disposition, must be expressed in Canada; and (ii) is not exempt from tax under Part I of the Tax Act (a “Resident Holder”)Canadian dollars. Certain Resident Holders whose Romarco Shares or OceanaGold Shares might not otherwise qualify as capital property may be entitled to have such shares, and all other “Canadian securities” (as defined in the Tax Act) owned by them in the taxation year and any subsequent taxation year, deemed to be capital property by making an irrevocable election in accordance with subsection 39(4) For purposes of the Tax Act. Resident Holders considering making such an election should consult their own tax advisors for advice as to whether , amounts denominated in U.S. dollars generally must be converted into Canadian dollars using the election is available or advisable appropriate exchange rate determined in their own particular circumstancesaccordance with the detailed rules in the Tax Act in that regard.