Common use of Foreign Tax Reporting Clause in Contracts

Foreign Tax Reporting. In accordance with the Intergovernmental Agreement between Canada and the United States for the enhanced exchange of tax information under the Canada-U.S. Tax Convention (the IGA) and related Canadian legislation and guidance, and as required under FATCA, the Fund, the Manager and/or registered dealers are required to report certain information with respect to Subscribers who are U.S. residents and U.S. citizens (including U.S. citizens who are residents or citizens of Canada), and certain other “U.S. Persons” as defined under the IGA, to the Canada Revenue Agency (CRA). The CRA is then expected to exchange the information with the U.S. Internal Revenue Service (IRS) pursuant to the provisions of the IGA. In addition, to meet the objectives of the CRS, the Fund, the Manager and/or the registered dealers are required under Canadian legislation to identify and report to the CRA details and certain financial information relating to unitholders in the Fund who are residents in a country outside of Canada and the U.S. which has adopted the CRS. It is expected that the CRA will then provide that information to the tax authorities of the relevant jurisdiction that has adopted the CRS. In order for the Manager and the Fund to comply with their obligations under the IGA and CRS, the Subscriber must complete the appropriate Declaration of Tax Residence Form for the purposes of Part XVIII [FATCA] and Part XIX [CRS] of the Income Tax Act (Canada) and will provide updated Forms upon reasonable request by the Manager, unless Schedule “C” has been completed by the Subscriber and the Subscriber has agreed to discharge such obligation. The Subscriber must immediately notify the Manager if any information on its forms changes. The Subscriber acknowledges that if the Manager is required to report information to the CRA in connection with the Subscriber’s investment in the Fund, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise.

Foreign Tax Reporting. In accordance with the Intergovernmental Agreement between Canada and the United States for the enhanced exchange of tax information under the Canada-U.S. Tax Convention (the IGA) and related Canadian legislation and guidance, and as required under FATCA, the Fund, the Manager and/or the registered dealers dealer are required to report certain information with respect to Subscribers who are U.S. residents and U.S. citizens (including U.S. citizens who are residents or citizens of Canada), and certain other “U.S. Persons” as defined under the IGA, to the Canada Revenue Agency (CRA). The CRA is then expected to exchange the information with the U.S. Internal Revenue Service (IRS) pursuant to the provisions of the IGA. In addition, to meet the objectives of the CRS, the Fund, the Manager and/or the registered dealers are required under Canadian legislation to identify and report to the CRA details and certain financial information relating to unitholders in the Fund who are residents in a country outside of Canada and the U.S. which has adopted the CRS. It is expected that the CRA will then provide that information to the tax authorities of the relevant jurisdiction that has adopted the CRS. In order for the Manager and the Fund to comply with their obligations under the IGA and CRS, the Subscriber must complete the appropriate Declaration of Tax Residence Form for the purposes of Part XVIII [FATCA] and Part XIX [CRS] of the Income Tax Act (Canada) and will provide updated Forms upon reasonable request by the Manager, unless Schedule “CB” has been completed by the Subscriber and the Subscriber has agreed to discharge such obligation. The Subscriber must immediately notify the Manager if any information on its forms Forms changes. The Subscriber acknowledges that if the Manager is required to report information to the CRA in connection with the Subscriber’s investment in the Fund, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise.

Foreign Tax Reporting. In accordance with the Intergovernmental Agreement between Canada and the United States for the enhanced exchange of tax information under the Canada-U.S. Tax Convention (the IGA) IGA and related Canadian legislation and guidance, and as required under FATCAthe U.S. Foreign Account Tax Compliance Act, the Trustee, the Fund, the Manager and/or registered dealers are required to report on behalf of the Fund certain information with respect to Subscribers who are U.S. residents and U.S. citizens (including U.S. citizens who are residents or citizens of Canada), and certain other “U.S. Persons” as defined under the IGA, to the Canada Revenue Agency (CRA). The CRA is will then expected to exchange the information with the U.S. Internal Revenue Service (IRS) IRS pursuant to the provisions of the IGA. In addition, to meet in accordance with CRS, the objectives of the CRSTrustee, the Fund, the Manager and/or the registered dealers are required under Canadian legislation to identify and report to the CRA details and certain financial information relating to unitholders securityholders in the Fund who are residents in a country outside of Canada and the U.S. which that has adopted the CRS. It is expected that the CRA will then provide that information to the tax authorities of the relevant jurisdiction that has adopted the CRS. In order for the Manager and the Fund to comply with their obligations under the IGA and CRS, the Subscriber must complete the appropriate Declaration of Tax Residence Form for the purposes of Part XVIII [FATCA] and Part XIX [CRS] of the Income Tax Act (Canada) and will provide updated Forms upon reasonable request by the Manager, unless Schedule “C” has been completed by the Subscriber and the Subscriber has agreed to discharge such obligation. The Subscriber must immediately notify the Manager if any information on its forms changes. The Subscriber acknowledges that if the Trustee, the Fund and/or the Manager is required to report information to the CRA in connection with the Subscriber’s investment in the Fund, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise. The Subscriber hereby covenants and agrees to complete and return a W-8 form (W-8BEN for individuals, W-8BEN-E for entities or W-8IMY for trusts or partnerships) immediately upon reasonable demand by the Fund, the Trustee or the Manager. The Subscriber hereby represents, warrants, covenants and agrees that the Subscriber shall, at the request of the Manager, provide such information and accurately complete and execute any and all documents, opinions, instruments, waivers and certificates as the Manager may reasonably require in order to establish: (i) the residence of the Subscriber for tax purposes; (ii) the entitlement of the Subscriber to claim the benefit afforded by a tax treaty; and/or (iii) whether any withholding may be required or an exemption therefrom, including in connection with any tax filings, and any and all other documents as the Manager determines are necessary or appropriate in order for the Fund to comply with applicable Canadian, United States or non-Canadian or non-United States laws, including tax laws (including all aspects of any tax information sharing regime), tax reporting obligations, tax withholding or tax payment obligations, including both currently applicable and any future laws that may be enacted to reduce any Canadian, United States or non-Canadian or non-United States tax that may be directly or indirectly imposed on the Fund, any Underlying Fund or any securityholder of the Fund or to comply with the requests or requirements of an applicable taxing authority. For greater certainty, the Subscriber hereby agrees that it shall also promptly provide such information, documentation, waiver or certification as may be requested by the Manager to determine whether any withholding may be required with respect to the Securities or in connection with tax filings in any jurisdiction in which or through which the Fund directly or indirectly invests, including any information, documentation, waiver or certification required for the Fund or any Underlying Fund to comply with any tax return or information filing requirements or to obtain a reduced rate of, or exemption from, any applicable tax or withholding requirement that may be imposed on the Fund or any Underlying Fund or any investor in the foregoing, or to comply with the requests or requirements of an applicable taxing authority. The Subscriber acknowledges and agrees that any such information, forms or documentation requested by the Manager pursuant to this paragraph, or any financial or account information with respect to the Subscriber’s investment in the Fund, may be disclosed to any withholding agent where the provision of that information is required by such agent to avoid the application of any applicable withholding tax and may be disclosed to applicable governmental authorities. If the Subscriber fails to comply with its obligations under this paragraph, or if it provides information or documentation that is in any way misleading, the Manager on behalf of the Fund reserves the right (whether or not such action or inaction leads to compliance failures by the Fund, or a risk of the Fund or its investors being subject to withholding tax or other penalties): (a) to take any action and/or pursue any or all remedies at its disposal including, without limitation, withdrawal of the Subscriber as a securityholder of the Fund; and (b) to cause the Subscriber to bear the economic burden of any taxes, liabilities, costs or expenses imposed (directly or indirectly) as a result of the Subscriber’s failure to comply with its obligations under this paragraph by specially allocating such taxes, liabilities, costs or expenses to the Subscriber and/or withholding such amounts from proceeds otherwise distributable to the Subscriber. In the event the Fund fails to withhold such amounts, the Subscriber further acknowledges that the Fund may require the Subscriber to reimburse the Fund or the Manager, as applicable, for such amounts. In addition, the Manager shall have full authority (but will not be required) to take any steps that the Manager reasonably determines are necessary or appropriate to mitigate the consequences to the Fund, any entity in which the Fund holds (directly or indirectly) an equity or debt interest and/or any other securityholder of the Fund of such Subscriber’s failure to comply with its obligations under this paragraph. The Subscriber hereby agrees to indemnify each of the Manager, the Trustee and the Fund and each of their respective principals, members, managers, officers, directors, stockholders, employees and agents, and agrees to hold each of them harmless, from and against any liability, action, proceeding, claim, demand, costs, damages, expenses (including legal expenses) penalties or taxes whatsoever that any of the foregoing may incur as a result of any breach by the Subscriber of its obligations under this paragraph. Bad Actor Disclosure The Subscriber hereby represents and warrants that it is not a Bad Actor (as defined below) and that no Bad Act (as defined below) exists with respect to the Subscriber or any person that indirectly controls the voting of the Subscriber’s Securities. The Subscriber agrees to provide the Fund any information that the Fund may reasonably request in order to determine whether the Subscriber or any person that indirectly controls the voting of the Subscriber’s Securities is a Bad Actor, including, without limitation, filings with, and records of, courts and regulators. The Subscriber agrees to notify the Fund of the Bad Acts of the Subscriber or any person that indirectly controls the voting of the Subscriber’s Securities promptly upon their occurrence.

Foreign Tax Reporting. In accordance with the Intergovernmental Agreement between Canada and the United States for the enhanced exchange of tax information under the Canada-U.S. Tax Convention (the IGA) IGA and related Canadian legislation and guidance, and as required under FATCAthe U.S. Foreign Account Tax Compliance Act, the Trustee, the Fund, the Manager and/or registered dealers are required to report on behalf of the Fund certain information with respect to Subscribers who are U.S. residents and U.S. citizens (including U.S. citizens who are residents or citizens of Canada), and certain other “U.S. Persons” as defined under the IGA, to the Canada Revenue Agency (CRA). The CRA is will then expected to exchange the information with the U.S. Internal Revenue Service (IRS) IRS pursuant to the provisions of the IGA. In addition, to meet in accordance with CRS, the objectives of the CRSTrustee, the Fund, the Manager and/or the registered dealers are required under Canadian legislation to identify and report to the CRA details and certain financial information relating to unitholders securityholders in the Fund who are residents in a country outside of Canada and the U.S. which that has adopted the CRS. It is expected that the CRA will then provide that information to the tax authorities of the relevant jurisdiction that has adopted the CRS. In order for the Manager and the Fund to comply with their obligations under the IGA and CRS, the Subscriber must complete the appropriate Declaration of Tax Residence Form for the purposes of Part XVIII [FATCA] and Part XIX [CRS] of the Income Tax Act (Canada) and will provide updated Forms upon reasonable request by the Manager, unless Schedule “C” has been completed by the Subscriber and the Subscriber has agreed to discharge such obligation. The Subscriber must immediately notify the Manager if any information on its forms changes. The Subscriber acknowledges that if the Trustee, the Fund and/or the Manager is required to report information to the CRA in connection with the Subscriber’s investment in the Fund, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise. The Subscriber hereby covenants and agrees to complete and return a W-8 form (W-8BEN for individuals, W-8BEN-E for entities or W-8IMY for trusts or partnerships) immediately upon reasonable demand by the Fund, the Trustee or the Manager. The Subscriber hereby represents, warrants, covenants and agrees that the Subscriber shall, at the request of the Manager, provide such information and accurately complete and execute any and all documents, opinions, instruments, waivers and certificates as the Manager may reasonably require in order to establish: (i) the residence of the Subscriber for tax purposes; (ii) the entitlement of the Subscriber to claim the benefit afforded by a tax treaty; and/or (iii) whether any withholding may be required or an exemption therefrom, including in connection with any tax filings, and any and all other documents as the Manager determines are necessary or appropriate in order for the Fund to comply with applicable Canadian or non-Canadian laws, including tax laws (including all aspects of any tax information sharing regime), tax reporting obligations, tax withholding or tax payment obligations, including both currently applicable and any future laws that may be enacted to reduce any Canadian or non-Canadian tax that may be directly or indirectly imposed on the Fund, the Master Fund or any securityholder of the Fund or to comply with the requests or requirements of an applicable taxing authority. For greater certainty, the Subscriber hereby agrees that it shall also promptly provide such information, documentation, waiver or certification as may be requested by the Manager to determine whether any withholding may be required with respect to the Securities or in connection with tax filings in any jurisdiction in which or through which the Fund directly or indirectly invests, including any information, documentation, waiver or certification required for the Fund or the Master Fund to comply with any tax return or information filing requirements or to obtain a reduced rate of, or exemption from, any applicable tax or withholding requirement that may be imposed on the Fund or the Master Fund or any investor in the foregoing, or to comply with the requests or requirements of an applicable taxing authority. The Subscriber acknowledges and agrees that any such information, forms or documentation requested by the Manager pursuant to this paragraph, or any financial or account information with respect to the Subscriber’s investment in the Fund, may be disclosed to any withholding agent where the provision of that information is required by such agent to avoid the application of any applicable withholding tax and may be disclosed to applicable governmental authorities. If the Subscriber fails to comply with its obligations under this paragraph, or if it provides information or documentation that is in any way misleading, the Manager on behalf of the Fund reserves the right (whether or not such action or inaction leads to compliance failures by the Fund, or a risk of the Fund or its investors being subject to withholding tax or other penalties): (a) to take any action and/or pursue any or all remedies at its disposal including, without limitation, withdrawal of the Subscriber as a securityholder of the Fund; and (b) to cause the Subscriber to bear the economic burden of any taxes, liabilities, costs or expenses imposed (directly or indirectly) as a result of the Subscriber’s failure to comply with its obligations under this paragraph by specially allocating such taxes, liabilities, costs or expenses to the Subscriber and/or withholding such amounts from proceeds otherwise distributable to the Subscriber. In the event the Fund fails to withhold such amounts, the Subscriber further acknowledges that the Fund may require the Subscriber to reimburse the Fund or the Manager, as applicable, for such amounts. In addition, the Manager shall have full authority (but will not be required) to take any steps that the Manager reasonably determines are necessary or appropriate to mitigate the consequences to the Fund, any entity in which the Fund holds (directly or indirectly) an equity or debt interest and/or any other securityholder of the Fund of such Subscriber’s failure to comply with its obligations under this paragraph. The Subscriber hereby agrees to indemnify each of the Manager, the Trustee and the Fund and each of their respective principals, members, managers, officers, directors, stockholders, employees and agents, and agrees to hold each of them harmless, from and against any liability, action, proceeding, claim, demand, costs, damages, expenses (including legal expenses) penalties or taxes whatsoever that any of the foregoing may incur as a result of any breach by the Subscriber of its obligations under this paragraph.

Foreign Tax Reporting. In accordance with Pursuant to the Foreign Account Tax Compliance Act (“FATCA”), Canada has entered into the Intergovernmental Agreement between Canada and the United States for the enhanced exchange Enhanced Exchange of tax information Tax Information under the Canada-U.S. United States Tax Convention convention (the IGA) “Agreement”), signed on February 5, 2014,. Furthermore, Canada's automatic exchange of financial account information arrangements with jurisdictions other than the U.S. has been implemented in accordance with the Organization for Economic Co-operation and related Development Common Reporting Standard (“CRS”), effective July 1, 2017. In accordance with this and under applicable Canadian legislation and guidance, and as required under FATCA, the Fundlegislation, the Manager and/or registered dealers are is required under Part XVIII and Part XIX of the Income Tax Act to collect the relevant information pertaining to the tax status of each Subscriber. The information is required to determine if the Manager is required to report certain information with respect to Subscribers who are U.S. residents and U.S. citizens (including U.S. citizens who are residents or citizens of Canada), and certain other “U.S. Persons” as defined under the IGA, Subscriber’s financial account to the Canada Revenue Agency (“CRA”). The CRA is then expected to exchange may share this information with the government of a foreign jurisdiction that you are resident of for tax purposes. In the case of the U.S. the CRA may also share the information with that country’s government if you are a U.S. Resident, U.S. Citizen or applicable U.S. Person, as defined in the U.S. Internal Revenue Service (IRS) pursuant to the provisions of the IGAAgreement. In addition, to meet the objectives of the CRS, the FundUnder CRS requirements, the Manager and/or the registered dealers are required under Canadian legislation to identify and must report to the CRA details and certain financial information relating to unitholders in the Fund subscribers who are residents in a country outside of Canada and the U.S. which has adopted the CRS. It The CRA is expected that the CRA will then to provide that information to the tax authorities of the relevant jurisdiction that has adopted the CRS. In order for the Manager and the Fund to comply with their obligations under the IGA and CRS, the Subscriber The Subscriber's Agent must complete the appropriate Declaration of Tax Residence Form for the purposes of Part XVIII [FATCA] and Part XIX [CRS] of the Income Tax Act (Canada) and will provide updated Forms upon reasonable request by the Manager, unless Schedule “C” has been completed by the Subscriber and the Subscriber has agreed to discharge such obligation. The Subscriber must immediately notify promptly inform the Manager if any of the information provided changes and may request information from the Manager on its forms changeswhether their account information has been reported to the CRA and what information was provided. The Subscriber acknowledges that if the Manager is required to report information to the CRA in connection with the Subscriber’s investment in the a Fund, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise. Furthermore the Subscriber acknowledges that it remains solely responsible for determining the tax status of the Investor and to comply with all related and applicable CRA due diligence and reporting requirements in that regard. Privacy Policy Attached as Schedule D hereto is a copy of the Manager’s Privacy Policy.

Foreign Tax Reporting. In accordance with The Subscriber acknowledges that the Intergovernmental Agreement between Manager on behalf of the Funds has due diligence and reporting obligations under the Foreign Account Tax Compliance Act (as implemented in Canada and the United States for the enhanced exchange of tax information under by the Canada-U.S. United States Enhanced Tax Convention (Information Exchange Agreement and Part XVIII of the IGATax Act, collectively “FATCA”) and related Canadian legislation and guidancethe OECD’s Common Reporting Standard (as implemented in Canada by Part XIX of the Tax Act, and as required under FATCA“CRS”). Generally, the FundSubscriber (or in the case of certain entities, its “controlling persons”) will be required by law to provide the Manager and/or registered dealers are required or their dealer with information related to report certain information with respect to Subscribers who are their citizenship or tax residence and, if applicable, their foreign tax identification number. If the Subscriber (or, if applicable, any of its controlling persons) (i) is identified as a U.S. residents and U.S. citizens citizen (including a U.S. citizens who are residents citizen living in Canada) or citizens a foreign (including U.S.) tax resident or (ii) does not provide the required information and indicia of Canada)U.S. or non-Canadian status is present, information about the Subscriber (or, if applicable, its controlling persons) and certain other “U.S. Persons” as defined under his, her or its investment in the IGA, Fund will generally be reported to the Canada Revenue Agency (“CRA)”) unless the Units are held within a registered plan. The CRA is then expected to exchange will provide that information to, in the information with case of FATCA, the U.S. Internal Revenue Service (IRS) pursuant to and in the provisions case of the IGA. In addition, to meet the objectives of the CRS, the Fund, the Manager and/or the registered dealers are required under Canadian legislation to identify and report to the CRA details and certain financial information relating to unitholders in the Fund who are residents in relevant tax authority of any country that is a country outside of Canada and the U.S. which has adopted the CRS. It is expected that the CRA will then provide that information to the tax authorities signatory of the relevant jurisdiction Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information or that has adopted the otherwise agreed to a bilateral information exchange with Canada under CRS. In order for the Manager and the Fund to comply with their its obligations under the IGA FATCA and CRS, the Subscriber must complete the appropriate Declaration of Tax Residence Form for the purposes of Part XVIII [FATCA] and Part XIX [CRS] of the Income Tax Act (Canada) and will provide updated Forms upon reasonable request by the Manager, unless Schedule “C” has been completed by the Subscriber and the Subscriber has agreed to discharge such obligation. The Subscriber must immediately notify the Manager if any information on its forms Form changes, unless Schedule “B” has been completed by the Subscriber’s Agent and the Subscriber’s Agent has agreed to discharge such obligation. The Subscriber acknowledges that if the Manager is required to report information to the CRA in connection with the Subscriber’s investment in the Fund, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise.

Foreign Tax Reporting. In accordance with The Subscriber acknowledges that the Intergovernmental Agreement between Manager on behalf of the Funds has due diligence and reporting obligations under the Foreign Account Tax Compliance Act (as implemented in Canada and the United States for the enhanced exchange of tax information under by the Canada-U.S. United States Enhanced Tax Convention (Information Exchange Agreement and Part XVIII of the IGATax Act, collectively “FATCA”) and related Canadian legislation and guidancethe OECD’s Common Reporting Standard (as implemented in Canada by Part XIX of the Tax Act, and as required under FATCA“CRS”). Generally, the FundSubscriber (or in the case of certain entities, its “controlling persons”) will be required by law to provide the Manager and/or registered dealers are required or their dealer with information related to report certain information with respect to Subscribers who are their citizenship or tax residence and, if applicable, their foreign tax identification number. If the Subscriber (or, if applicable, any of its controlling persons) (i) is identified as a U.S. residents and U.S. citizens citizen (including a U.S. citizens who are residents citizen living in Canada) or citizens a foreign (including U.S.) tax resident or (ii) does not provide the required information and indicia of Canada)U.S. or non-Canadian status is present, information about the Subscriber (or, if applicable, its controlling persons) and certain other “U.S. Persons” as defined under his, her or its investment in the IGA, Fund will generally be reported to the Canada Revenue Agency (“CRA)”) unless the Units are held within a registered plan. The CRA is then expected to exchange will provide that information to, in the information with case of FATCA, the U.S. Internal Revenue Service (IRS) pursuant to and in the provisions case of the IGA. In addition, to meet the objectives of the CRS, the Fund, the Manager and/or the registered dealers are required under Canadian legislation to identify and report to the CRA details and certain financial information relating to unitholders in the Fund who are residents in relevant tax authority of any country that is a country outside of Canada and the U.S. which has adopted the CRS. It is expected that the CRA will then provide that information to the tax authorities signatory of the relevant jurisdiction Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information or that has adopted the otherwise agreed to a bilateral information exchange with Canada under CRS. In order for the Manager and the Fund to comply with their its obligations under the IGA FATCA and CRS, the Subscriber must complete the appropriate Declaration of Tax Residence Form for the purposes of Part XVIII [FATCA] and Part XIX [CRS] of the Income Tax Act (Canada) and will provide updated Forms upon reasonable request by immediately notify the ManagerManager if any information on its Form changes, unless Schedule “C” has been completed by the Subscriber Subscriber’s Agent and the Subscriber Subscriber’s Agent has agreed to discharge such obligation. The Subscriber must immediately notify the Manager if any information on its forms changes. The Subscriber acknowledges that if the Manager is required to report information to the CRA in connection with the Subscriber’s investment in the Fund, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise.

Foreign Tax Reporting. In accordance with the Intergovernmental Agreement between Canada and the United States for the enhanced exchange of tax information under the Canada-U.S. Tax Convention (the “IGA”) and related Canadian legislation and guidance, and as required under the U.S. Foreign Account Tax Compliance Act (“FATCA”), the Fund, the Manager and/or registered dealers we are required to report on behalf of each Fund certain information with respect to Subscribers investors who are U.S. residents and U.S. citizens (including U.S. citizens who are residents or citizens of Canada), and certain other “U.S. Persons” as defined under the IGA, to the Canada Revenue Agency (“CRA”). The CRA is will then expected to exchange the information with the U.S. Internal Revenue Service (IRS) pursuant to the provisions of the IGA. In addition, to meet the objectives of the Organization for Economic Co-operation and Development Common Reporting Standard (the “CRS”), the Fund, the Manager and/or the registered dealers are each RP Fund and RPIA may be required under Canadian legislation to identify and report to the CRA details and certain financial information relating to unitholders investors in the Fund fund who are residents for tax purposes in a country outside of Canada and the U.S. which has adopted the CRS. It is expected that the The CRA will then provide that information to the tax authorities of the relevant jurisdiction that has adopted the CRS. In order for the Manager and the Fund us to comply with their our obligations under the IGA and CRS, the Subscriber all Clients must complete provide the appropriate Declaration of Tax Residence Form information required for the purposes of Part XVIII [FATCA] and Part XIX [CRS] of the Income Tax Act (Canada) ), in the form provided as part of this Client Agreement. You must immediately notify us if any information on your completed form changes and will must provide an updated Forms form upon reasonable request by the Manager, unless Schedule “C” has been completed by the Subscriber and the Subscriber has agreed to discharge such obligationus. The Subscriber must immediately notify the Manager if any information on its forms changes. The Subscriber acknowledges You acknowledge that if the Manager is we are required to report information to the CRA in connection with the Subscriber’s investment in the Fundyour investment, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise.. Relationship Disclosure Information The Client(s) acknowledges that RPIA is the dealer of record in respect of your purchase of units of the Fund(s). As dealer, RPIA is required by law to provide certain information to the Client(s) (referred to as “relationship disclosure information”) regarding the Nature of the relationship between RPIA and the Client(s), the operating charges and transaction charges charged by RPIA to the Client(s) or the Fund(s), and the obligations of RPIA to the Client(s), among other things, which is detailed in the Relationship Disclosure Information form. Conflict of Interest Disclosure The Conflict of Interest Disclosure provides you, as a Dealer client of RPIA with a description of the relevant material conflicts, the nature and extent of the conflict, the potential impact and risk that the conflict could pose to a client, and how the conflict has been or will be addressed. RPIA is committed to acting with a high level of professionalism and integrity and is committed to placing the Client’s interest head of its own or that of an employee of other stakeholder.. Please refer to our Conflicts of Interest Disclosure Statement. Complaints and Independent Dispute Resolution Service Information and disclosure regarding our complaints process and independent dispute resolution service available to a Client(s) is attached as Schedule C.

Foreign Tax Reporting. In accordance with the Intergovernmental Agreement between Canada and the United States for the enhanced exchange of tax information under the Canada-U.S. Tax Convention (the “IGA”) and related Canadian proposed legislation and guidance, and as required under the U.S. Foreign Account Tax Compliance Act (“FATCA”), the Fund, the Manager and/or registered dealers are Advisor is required to report on behalf of the Partnership certain information with respect to Subscribers who are U.S. residents and U.S. citizens (including U.S. citizens who are residents or citizens of Canada), and certain other “U.S. Persons” as defined under the IGA, to the Canada Revenue Agency (“CRA”). The CRA is will then expected to exchange the information with the U.S. Internal Revenue Service (“IRS”) pursuant to the provisions of the IGA. In addition, to meet the objectives of the CRS, the Fund, the Manager and/or the registered dealers are required under Canadian legislation to identify and report to the CRA details and certain financial information relating to unitholders in the Fund who are residents in a country outside of Canada and the U.S. which has adopted the CRS. It is expected that the CRA will then provide that information to the tax authorities of the relevant jurisdiction that has adopted the CRS. In order for the Manager Advisor and the Fund Partnership to comply with their obligations under the IGA and CRSIGA, the Subscriber all Subscribers must complete Schedule “G”, and must immediately notify the appropriate Declaration of Tax Residence Form for the purposes of Part XVIII [FATCA] and Part XIX [CRS] of the Income Tax Act (Canada) and will provide updated Forms upon reasonable request by the ManagerAdvisor if any information provided on Schedule “G” changes, unless Schedule “CB” has been completed by the Subscriber and the Subscriber Subscriber’s Agent has agreed to discharge such obligation. The Subscriber must immediately notify obligations by checking the Manager if any information “Yes” box on its forms changesSchedule “B”. The Subscriber acknowledges that if the Manager Advisor is required to report information to the CRA in connection with the Subscriber’s investment in the FundPartnership, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise. Statutory Rights of Action Subscribers resident in certain provinces and territories are entitled by applicable legislation to rights of action for damages or rescission as described in the Offering Memorandum. Such rights of action for damages or rescission shall be exercised by delivery of notice in writing by the Subscriber to the Partnership at 000 Xxx Xxxxxx, Xxxxx 0000 XX Xxx 00 Xxxxxxx, XX X0X 0X0 (or at such other address as the Partnership may direct, from time to time) within the time period specified in the legislation.

Foreign Tax Reporting. In accordance with Pursuant to the Foreign Account Tax Compliance Act (“FATCA”), Canada has entered into the Intergovernmental Agreement between Canada and the United States for the enhanced exchange Enhanced Exchange of tax information Tax Information under the Canada-U.S. United States Tax Convention convention (the IGA) “Agreement”), signed on February 5, 2014,. Furthermore, Canada's automatic exchange of financial account information arrangements with jurisdictions other than the U.S. has been implemented in accordance with the Organization for Economic Co-operation and related Development Common Reporting Standard (“CRS”), effective July 1, 2017. In accordance with this and under applicable Canadian legislation and guidance, and as required under FATCA, the Fundlegislation, the Manager and/or registered dealers are is required under Part XVIII and Part XIX of the Income Tax Act to collect the relevant information pertaining to the tax status of each Subscriber. The information is required to determine if the Manager is required to report certain information with respect to Subscribers who are U.S. residents and U.S. citizens (including U.S. citizens who are residents or citizens of Canada), and certain other “U.S. Persons” as defined under the IGA, Subscriber’s financial account to the Canada Revenue Agency (“CRA”). The CRA is then expected to exchange may share this information with the government of a foreign jurisdiction that you are resident of for tax purposes. In the case of the U.S. the CRA may also share the information with that country’s government if you are a U.S. Resident, U.S. Citizen or applicable U.S. Person, as defined in the U.S. Internal Revenue Service (IRS) pursuant to the provisions of the IGAAgreement. In addition, to meet the objectives of the CRS, the FundUnder CRS requirements, the Manager and/or the registered dealers are required under Canadian legislation to identify and must report to the CRA details and certain financial information relating to unitholders in the Fund subscribers who are residents in a country outside of Canada and the U.S. which has adopted the CRS. It The CRA is expected that the CRA will then to provide that information to the tax authorities of the relevant jurisdiction that has adopted the CRS. In order for the Manager and the Fund to comply with their obligations under the IGA and CRS, the Subscriber The Subscriber's Agent must complete the appropriate Declaration of Tax Residence Form for the purposes of Part XVIII [FATCA] and Part XIX [CRS] of the Income Tax Act (Canada) and will provide updated Forms upon reasonable request by the Manager, unless Schedule “C” has been completed by the Subscriber and the Subscriber has agreed to discharge such obligation. The Subscriber must immediately notify promptly inform the Manager if any of the information provided changes and may request information from the Manager on its forms changeswhether their account information has been reported to the CRA and what information was provided. The Subscriber acknowledges that if the Manager is required to report information to the CRA in connection with the Subscriber’s investment in the a Fund, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise. Furthermore the Subscriber acknowledges that it remains solely responsible for determining the tax status of the Investor and to comply with all related and applicable CRA due diligence and reporting requirements in that regard. Privacy Policy Attached as Schedule C hereto is a copy of the Manager’s Privacy Policy. By signing this Subscription Agreement, the Subscriber consents to the collection, use and disclosure of his or her personal information in accordance with such policy.

Foreign Tax Reporting. In accordance with the Intergovernmental Agreement between Canada and the United States for the enhanced exchange of tax information under the Canada-U.S. Tax Convention (the “IGA”) and related Canadian legislation and guidance, and as required under the U.S. Foreign Account Tax Compliance Act (“FATCA, the Fund”), the Manager and/or registered dealers are is required to report on behalf of the Fund certain information with respect to Subscribers who are U.S. residents and U.S. citizens (including U.S. citizens who are residents or citizens of Canada), and certain other “U.S. Persons” as defined under the IGA, to the Canada Revenue Agency (“CRA”). The CRA is will then expected to exchange the information with the U.S. Internal Revenue Service (IRS) pursuant to the provisions of the IGA. In addition, to meet the objectives of the Organization for Economic Co-operation and Development Common Reporting Standard (the “CRS”), the Fund, Fund and the Manager and/or the registered dealers are required under Canadian legislation to identify and report to the CRA details and certain financial information relating to unitholders Unitholders in the Fund who are residents in a country outside of Canada and the U.S. which that has adopted the CRS. It is expected that the The CRA will then provide that information to the tax authorities of the relevant jurisdiction that has adopted the CRS. In order for the Manager and the Fund to comply with their obligations under the IGA and CRS, the Subscriber all Subscribers must complete provide the appropriate Declaration of Tax Residence Form for the purposes of Part XVIII [FATCA] and Part XIX [CRSCommon Reporting Standard] of the Income Tax Act (Canada) ), and will provide an updated Forms Form upon reasonable request by the Manager, unless Schedule “C” has been completed by the Subscriber and the Subscriber has agreed to discharge such obligation. The Subscriber must immediately notify the Manager if any information on its forms Form changes. The Subscriber acknowledges that if the Manager is required to report information to the CRA in connection with the Subscriber’s investment in the Fund, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise.

Foreign Tax Reporting. In accordance with the Intergovernmental Agreement between Canada and the United States for the enhanced exchange of tax information under the Canada-U.S. Tax Convention (the IGA) IGA and related Canadian legislation and guidance, and as required under FATCAthe U.S. Foreign Account Tax Compliance Act, the FundGeneral Partner, the Partnership, the Manager and/or registered dealers are required to report on behalf of the Partnership certain information with respect to Subscribers who are U.S. residents and U.S. citizens (including U.S. citizens who are residents or citizens of Canada), and certain other “U.S. Persons” as defined under the IGA, to the Canada Revenue Agency (CRA). The CRA is will then expected to exchange the information with the U.S. Internal Revenue Service (IRS) IRS pursuant to the provisions of the IGA. In addition, to meet the objectives of the in accordance with CRS, the FundGeneral Partner, the Partnership, the Manager and/or the registered dealers Registered Dealers are required under Canadian legislation to identify and report to the CRA details and certain financial information relating to unitholders in the Fund Partnership who are residents in a country outside of Canada and the U.S. which that has adopted the CRS. It is expected that the CRA will then provide that information to the tax authorities of the relevant jurisdiction that has adopted the CRS. In order for the Manager and the Fund to comply with their obligations under the IGA and CRS, the Subscriber must complete the appropriate Declaration of Tax Residence Form for the purposes of Part XVIII [FATCA] and Part XIX [CRS] of the Income Tax Act (Canada) and will provide updated Forms upon reasonable request by the Manager, unless Schedule “C” has been completed by the Subscriber and the Subscriber has agreed to discharge such obligation. The Subscriber must immediately notify the Manager if any information on its forms changes. The Subscriber acknowledges that if the General Partner, the Partnership and/or the Manager is required to report information to the CRA in connection with the Subscriber’s investment in the FundPartnership, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise. The Subscriber covenants and agrees to provide, in a timely manner, such information and such forms or documentation as may be requested from time to time in connection with the Partnership’s investments in the Boothbay International Fund and/or the Master Fund in order to comply with the requirements and obligations imposed on them pursuant to AEOI (defined below), and the Subscriber acknowledges and agrees that any such information, forms or documentation or any financial or account information with respect to the Subscriber’s investment hereunder may be disclosed to the Cayman Islands Tax Information Authority (or any other Cayman Islands governmental body that collects information in accordance with AEOI) and to any withholding agent in connection with the avoidance of the application of withholding tax. The Subscriber covenants and agrees to provide, upon request, a waiver of the provisions of any law that: (A) prohibits the disclosure by the Boothbay International Fund and/or the Master Fund, or by any of their agents, of the information or documentation requested from the Subscriber or the Partnership in connection with the Partnership’s investment in such entities; or (B) prohibits the reporting of financial or account information by the Boothbay International Fund and/or the Master Fund or their agents required pursuant to AEOI; or (C) otherwise prevents compliance by the Boothbay International Fund and/or the Master Fund with their obligations under AEOI.

Foreign Tax Reporting. In accordance with the Intergovernmental Agreement between Canada and the United States for the enhanced exchange of tax information under the Canada-U.S. Tax Convention (the IGA) IGA and related Canadian legislation and guidance, and as required under FATCAthe U.S. Foreign Account Tax Compliance Act, the FundGeneral Partner, the Partnership, the Manager and/or registered dealers are required to report on behalf of the Partnership certain information with respect to Subscribers who are U.S. residents and U.S. citizens (including U.S. citizens who are residents or citizens of Canada), and certain other “U.S. Persons” as defined under the IGA, to the Canada Revenue Agency (CRA). The CRA is will then expected to exchange the information with the U.S. Internal Revenue Service (IRS) IRS pursuant to the provisions of the IGA. In addition, to meet the objectives of the in accordance with CRS, the FundGeneral Partner, the Partnership, the Manager and/or the registered dealers are required under Canadian legislation to identify and report to the CRA details and certain financial information relating to unitholders in the Fund Partnership who are residents in a country outside of Canada and the U.S. which has adopted the CRS. It is expected that the CRA will then provide that information to the tax authorities of the relevant jurisdiction that has adopted the CRS. In order for the Manager and the Fund to comply with their obligations under the IGA and CRS, the Subscriber must complete the appropriate Declaration of Tax Residence Form for the purposes of Part XVIII [FATCA] and Part XIX [CRS] of the Income Tax Act (Canada) and will provide updated Forms upon reasonable request by the Manager, unless Schedule “C” has been completed by the Subscriber and the Subscriber has agreed to discharge such obligation. The Subscriber must immediately notify the Manager if any information on its forms changes. The Subscriber acknowledges that if the General Partner, the Partnership and/or the Manager is required to report information to the CRA in connection with the Subscriber’s investment in the FundPartnership, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise. The Subscriber covenants and agrees to provide, in a timely manner, such information and such forms or documentation as may be requested from time to time in connection with the Partnership’s investments in iCapital International Fund and/or the Underlying Fund in order to comply with the requirements and obligations imposed on them pursuant to AEOI (defined below), and the Subscriber acknowledges and agrees that any such information, forms or documentation or any financial or account information with respect to the Subscriber’s investment hereunder may be disclosed may be disclosed to the Cayman Islands Tax Information Authority (or any other Cayman Islands governmental body which collects information in accordance with AEOI) and to any withholding agent in connection with the avoidance of the application of withholding tax. The Subscriber covenants and agrees to provide, upon request, a waiver of the provisions of any law that (A) prohibit the disclosure by the iCapital International Fund and/or the Underlying Fund, or by any of their agents, of the information or documentation requested from the Subscriber or the Partnership in connection with the Partnership’s investment in such entities; or (B) prohibit the reporting of financial or account information by iCapital International Fund and/or the Underlying Fund or their agents required pursuant to AEOI; or (C) otherwise prevent compliance by iCapital International Fund and/or the Underlying Fund with their obligations under AEOI.

Foreign Tax Reporting. In accordance with the Intergovernmental Agreement between Canada and the United States for the enhanced exchange of tax information under the Canada-U.S. Tax Convention (the “IGA”) and related Canadian proposed legislation and guidance, and as required under the U.S. Foreign Account Tax Compliance Act (“FATCA”), the Fund, the Manager and/or registered dealers are Advisor is required to report on behalf of the Partnership certain information with respect to Subscribers who are U.S. residents and U.S. citizens (including U.S. citizens who are residents or citizens of Canada), and certain other “U.S. Persons” as defined under the IGA, to the Canada Revenue Agency (“CRA”). The CRA is will then expected to exchange the information with the U.S. Internal Revenue Service (“IRS”) pursuant to the provisions of the IGA. In addition, to meet the objectives of the CRS, the Fund, the Manager and/or the registered dealers are required under Canadian legislation to identify and report to the CRA details and certain financial information relating to unitholders in the Fund who are residents in a country outside of Canada and the U.S. which has adopted the CRS. It is expected that the CRA will then provide that information to the tax authorities of the relevant jurisdiction that has adopted the CRS. In order for the Manager Advisor and the Fund Partnership to comply with their obligations under the IGA and CRSIGA, the Subscriber all Subscribers must complete Schedule “G”, and must immediately notify the appropriate Declaration of Tax Residence Form for the purposes of Part XVIII [FATCA] and Part XIX [CRS] of the Income Tax Act (Canada) and will provide updated Forms upon reasonable request by the ManagerAdvisor if any information provided on Schedule “G” changes, unless Schedule “CB” has been completed by the Subscriber and the Subscriber Subscriber’s Agent has agreed to discharge such obligation. The Subscriber must immediately notify obligations by checking the Manager if any information “Yes” box on its forms changesSchedule “B”. The Subscriber acknowledges that if the Manager Advisor is required to report information to the CRA in connection with the Subscriber’s investment in the FundPartnership, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise. Statutory Rights of Action Subscribers resident in certain provinces and territories are entitled by applicable legislation to rights of action for damages or rescission as described in the Offering Memorandum. Such rights of action for damages or rescission shall be exercised by delivery of notice in writing by the Subscriber to the Partnership at 00 Xxxx Xx Xxxx, Xxxxx 0000, XX Xxx 000, Xxxxxxx, XX X0X 0X0 (or at such other address as the Partnership may direct, from time to time) within the time period specified in the legislation.

Foreign Tax Reporting. In accordance with the Intergovernmental Agreement between Canada and the United States for the enhanced exchange of tax information under the Canada-U.S. Tax Convention (the “IGA”) and related Canadian proposed legislation and guidance, and as required under the U.S. Foreign Account Tax Compliance Act (“FATCA, the Fund”), the Manager and/or registered dealers are is required to report on behalf of the Trust certain information with respect to Subscribers who are U.S. residents and U.S. citizens (including U.S. citizens who are residents or citizens of Canada), and certain other “U.S. Persons” as defined under the IGA, to the Canada Revenue Agency (“CRA”). The CRA is will then expected to exchange the information with the U.S. Internal Revenue Service (“IRS”) pursuant to the provisions of the IGA. In addition, to meet the objectives of the CRS, the Fund, the Manager and/or the registered dealers are required under Canadian legislation to identify and report to the CRA details and certain financial information relating to unitholders in the Fund who are residents in a country outside of Canada and the Canada-U.S. which has adopted the CRS. It is expected that the CRA will then provide that information to the tax authorities of the relevant jurisdiction that has adopted the CRSTax Convention. In order for the Manager and the Fund Trust to comply with their obligations under the IGA and CRSIGA, the Subscriber all Subscribers must complete the appropriate Declaration of Tax Residence a Form for the purposes of Part XVIII [FATCA] and Part XIX [CRS] of the Income Tax Act (Canada) and will provide updated Forms upon reasonable request by the Manager, unless Schedule “C” has been completed by the Subscriber and the Subscriber has agreed to discharge such obligation. The Subscriber must immediately notify the Manager if any information on its forms changes. W-8BEN or W-8BEN-E. The Subscriber acknowledges that if the Manager is required to report information to the CRA in connection with the Subscriber’s investment in the FundTrust, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise. Policy Concerning Conflicts of Interest with Related Issuers and Connected Issuers Attached as Schedule “E” hereto is a summary of the Manager’s policy concerning conflicts of interest with related issuers and connected issuers. By signing this Subscription Agreement, the Subscriber acknowledges that he, she or it has read such disclosure and (i) is aware that (A) there are issuers which may be considered as “related” or “connected” to the Manager; (B) the Manager may trade or provide advice with respect to the securities of such issuers; and (C) the Manager and/or an affiliate may be paid certain fees or receive other compensation from such issuers in exchange for services; and (ii) unless the Subscriber withholds his, her or its consent from the Manager in writing, consents to the Trust investing in securities of such issuers.

Foreign Tax Reporting. In accordance with the Intergovernmental Agreement between Canada and the United States for the enhanced exchange of tax information under the Canada-U.S. Tax Convention (the “IGA”) and related Canadian proposed legislation and guidance, and as required under the U.S. Foreign Account Tax Compliance Act (“FATCA, the Fund”), the Manager and/or registered dealers are is required to report on behalf of the Partnership certain information with respect to Subscribers who are U.S. residents and U.S. citizens (including U.S. citizens who are residents or citizens of Canada), and certain other “U.S. Persons” as defined under the IGA, to the Canada Revenue Agency (“CRA”). The CRA is will then expected to exchange the information with the U.S. Internal Revenue Service (“IRS”) pursuant to the provisions of the IGA. In addition, to meet the objectives of the CRS, the Fund, the Manager and/or the registered dealers are required under Canadian legislation to identify and report to the CRA details and certain financial information relating to unitholders in the Fund who are residents in a country outside of Canada and the Canada-U.S. which has adopted the CRS. It is expected that the CRA will then provide that information to the tax authorities of the relevant jurisdiction that has adopted the CRSTax Convention. In order for the Manager and the Fund Partnership to comply with their obligations under the IGA and CRSIGA, the Subscriber all Subscribers must complete the appropriate Declaration of Tax Residence a Form for the purposes of Part XVIII [FATCA] and Part XIX [CRS] of the Income Tax Act (Canada) and will provide updated Forms upon reasonable request by the Manager, unless Schedule “C” has been completed by the Subscriber and the Subscriber has agreed to discharge such obligation. The Subscriber must immediately notify the Manager if any information on its forms changes. W-8BEN or W-8BEN-E. The Subscriber acknowledges that if the Manager is required to report information to the CRA in connection with the Subscriber’s investment in the FundPartnership, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise. Policy Concerning Conflicts of Interest with Related Issuers and Connected Issuers Attached as Schedule “E” hereto is a summary of the Manager’s policy concerning conflicts of interest with related issuers and connected issuers. By signing this Subscription Agreement, the Subscriber acknowledges that he, she or it has read such disclosure and (i) is aware that (A) there are issuers which may be considered as “related” or “connected” to the Manager; (B) the Manager may trade or provide advice with respect to the securities of such issuers; and (C) the Manager and/or an affiliate may be paid certain fees or receive other compensation from such issuers in exchange for services; and (ii) unless the Subscriber withholds his, her or its consent from the Manager in writing, consents to the Partnership investing in securities of such issuers.

Foreign Tax Reporting. In accordance with the Intergovernmental Agreement between Canada and the United States for the enhanced exchange of tax information under the Canada-U.S. Tax Convention (the “IGA”) and related Canadian legislation and guidance, and as required under the U.S. Foreign Account Tax Compliance Act (“FATCA”), the Fund, the Manager and/or registered dealers we are required to report on behalf of each RP Fund certain information with respect to Subscribers investors who are U.S. residents and U.S. citizens (including U.S. citizens who are residents or citizens of Canada), and certain other “U.S. Persons” as defined under the IGA, to the Canada Revenue Agency (“CRA”). The CRA is will then expected to exchange the information with the U.S. Internal Revenue Service (IRS) pursuant to the provisions of the IGA. In addition, to meet the objectives of the Organization for Economic Co-operation and Development Common Reporting Standard (the “CRS”), the Fund, each RP Fund and the Manager and/or the registered dealers are may be required under Canadian legislation to identify and report to the CRA details and certain financial information relating to unitholders investors in the Fund fund who are residents for tax purposes in a country outside of Canada and the U.S. which has adopted the CRS. It is expected that the U.S.. The CRA will then provide that information to the tax authorities of the relevant jurisdiction that has adopted the CRS. In order for the Manager and the Fund us to comply with their our obligations under the IGA and CRS, the Subscriber all Clients must complete provide the appropriate Declaration of Tax Residence Form for the purposes of Part XVIII [FATCA] and Part XIX [CRS] of the Income Tax Act (Canada) ), which forms part of this Client Agreement. You must immediately notify us if any information on your completed form changes and will must provide an updated Forms form upon reasonable request by the Manager, unless Schedule “C” has been completed by the Subscriber and the Subscriber has agreed to discharge such obligationus. The Subscriber must immediately notify the Manager if any information on its forms changes. The Subscriber acknowledges You acknowledge that if the Manager is we are required to report information to the CRA in connection with the Subscriber’s investment in the Fundyour investment, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise.. Privacy Policy Attached as Schedule A hereto is a copy of the Manager’s Privacy Policy. By signing this Client Agreement, the Client consents to the collection, use and disclosure of his or her personal information in accordance with such policy Relationship Disclosure Information The Client acknowledges that the Manager is the dealer of record in respect of your purchase of units of the Fund(s). As dealer, the Manager is required by law to provide certain information to the Client (referred to as “relationship disclosure information”) regarding the nature of the relationship between the Manager and the Client, the operating charges and transaction charges charged by the Manager to the Client or the Fund(s), and the obligations of the Manager to the Client, among other things, which is detailed in the Relationship Disclosure Information and Conflict of Interest Disclosure Document Conflict of Interest Disclosure The Conflict of Interest Disclosure provides you, as a Dealer client of RPIA with a description of the relevant material conflicts, the nature and extent of the conflict, the potential impact and risk that the conflict could pose to a client, and how the conflict has been or will be addressed. RPIA is committed to acting with a high level of professionalism and integrity and is focused on keeping your best interest as a fundamental element of our business practices. Details of the Conflict of Interest Disclosure Statement can be found in the Relationship Disclosure Information and Conflict of Interest Disclosure Document. Independent Dispute Resolution Service Disclosure regarding the complaints process and independent dispute resolution service available to the Client is attached as Schedule C.

Foreign Tax Reporting. In accordance with the Intergovernmental Agreement between Canada and the United States for the enhanced exchange of tax information under the Canada-U.S. Tax Convention (the IGA) and related Canadian legislation and guidance, and as required under the U.S. Foreign Account Tax Compliance Act (FATCA), the Fund, the Manager and/or registered dealers are WML is required to report on behalf of WMIC certain information with respect to Subscribers who are U.S. residents and U.S. citizens (including U.S. citizens who are residents or citizens of Canada), and certain other “U.S. Persons” as defined under the IGA, to the Canada Revenue Agency (CRA). The CRA is will then expected to exchange the information with the U.S. Internal Revenue Service (IRS) pursuant to the provisions of the IGA. In addition, to meet the objectives of the Organization for Economic Co- operation and Development Common Reporting Standard (the CRS), the Fund, the Manager and/or the registered dealers are WMIC and WML may be required under Canadian legislation to identify and report to the CRA details and certain financial information relating to unitholders in the Fund Subscribers who are residents for tax purposes in a country outside of Canada and the U.S. which that has adopted the CRS. It is expected that the The CRA will then provide that information to the tax authorities of the relevant jurisdiction that has adopted the CRS. In order for the Manager and the Fund WMIC to comply with their its obligations under the IGA and CRS, the Subscriber all Subscribers must complete provide the appropriate Declaration of Tax Residence Form for the purposes of Part XVIII [FATCA] and Part XIX [CRSCommon Reporting Standard] of the Income Tax Act (Canada) ), and will provide an updated Forms form upon reasonable request by the Manager, unless Schedule “C” has been completed by the Subscriber and the Subscriber has agreed to discharge such obligationWMIC. The Subscriber must immediately notify the Manager WML if any information on its forms form changes. The Subscriber acknowledges that if the Manager WML is required to report information to the CRA in connection with the Subscriber’s investment in the FundWMIC, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise.

Foreign Tax Reporting. In accordance with The Manager has due diligence and reporting obligations under the Intergovernmental Agreement between Foreign Account Tax Compliance Act (as implemented in Canada and the United States for the enhanced exchange of tax information under by the Canada-U.S. United States Enhanced Tax Convention (Information Exchange Agreement and Part XVIII of the IGATax Act, collectively “FATCA”) and related Canadian legislation and guidancethe OECD’s Common Reporting Standard (as implemented in Canada by Part XIX of the Tax Act, and as required under FATCA“CRS”). Generally, Subscribers (or in the case of certain Subscribers that are entities, the Fund, “controlling persons” thereof) will be required by law to provide the Manager and/or registered dealers are required (or their dealer) with information related to report certain information with respect to Subscribers who are their citizenship or tax residence and, if applicable, their foreign tax identification number. If the Subscriber (or, if applicable, any of its controlling persons) (i) is identified as a U.S. residents and U.S. citizens citizen (including a U.S. citizens who are residents citizen living in Canada) or citizens a foreign (including U.S.) tax resident or (ii) does not provide the required information and indicia of Canada)U.S. or non-Canadian status is present, information about the Subscriber (or, if applicable, its controlling persons) and certain other “U.S. Persons” as defined under his, her or its investment in the IGA, Fund will generally be reported to the Canada Revenue Agency (“CRA”). The CRA is then expected to exchange will provide that information to, in the information with case of FATCA, the U.S. Internal Revenue Service (IRS) pursuant to and in the provisions case of the IGA. In addition, to meet the objectives of the CRS, the Fund, the Manager and/or the registered dealers are required under Canadian legislation to identify and report to the CRA details and certain financial information relating to unitholders in the Fund who are residents in relevant tax authority of any country that is a country outside of Canada and the U.S. which has adopted the CRS. It is expected that the CRA will then provide that information to the tax authorities signatory of the relevant jurisdiction Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information or that has adopted the otherwise agreed to a bilateral information exchange with Canada under CRS. In order for the Manager and the Fund to comply with their its obligations under the IGA FATCA and CRS, the Subscriber must complete provide the appropriate Declaration of Tax Residence Form for the purposes of Part XVIII [FATCA] 518 or 519, as applicable, and Part XIX [CRS] of the Income Tax Act (Canada) and will must provide an updated Forms form upon reasonable request by the Manager, unless Schedule “CB” has been completed by the Subscriber and the Subscriber Subscriber’s Agent has agreed to discharge such obligation. The Subscriber must immediately notify obligations by checking the Manager if any information “Yes” box on its forms changesSchedule “B”. The Subscriber acknowledges that if the Manager is required to report information to the CRA in connection with the Subscriber’s investment in the Fund, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise.

Foreign Tax Reporting. In accordance with Pursuant to the Foreign Account Tax Compliance Act (“FATCA”), Canada has entered into the Intergovernmental Agreement between Canada and the United States for the enhanced exchange Enhanced Exchange of tax information Tax Information under the Canada-U.S. United States Tax Convention convention (the IGA) “Agreement”), signed on February 5, 2014,. Furthermore, Canada's automatic exchange of financial account information arrangements with jurisdictions other than the U.S. has been implemented in accordance with the Organization for Economic Co-operation and related Development Common Reporting Standard (“CRS”), effective July 1, 2017. In accordance with this and under applicable Canadian legislation and guidance, and as required under FATCA, the Fundlegislation, the Manager and/or registered dealers are is required under Part XVIII and Part XIX of the Income Tax Act to collect the relevant information pertaining to the tax status of each Subscriber. The information is required to determine if the Manager is required to report certain information with respect to Subscribers who are U.S. residents and U.S. citizens (including U.S. citizens who are residents or citizens of Canada), and certain other “U.S. Persons” as defined under the IGA, Subscriber’s financial account to the Canada Revenue Agency (“CRA”). The CRA is then expected to exchange may share this information with the government of a foreign jurisdiction that you are resident of for tax purposes. In the case of the U.S. the CRA may also share the information with that country’s government if you are a U.S. Resident, U.S. Citizen or applicable U.S. Person, as defined in the U.S. Internal Revenue Service (IRS) pursuant to the provisions of the IGAAgreement. In addition, to meet the objectives of the CRS, the FundUnder CRS requirements, the Manager and/or the registered dealers are required under Canadian legislation to identify and must report to the CRA details and certain financial information relating to unitholders in the Fund subscribers who are residents in a country outside of Canada and the U.S. which has adopted the CRS. It The CRA is expected that the CRA will then to provide that information to the tax authorities of the relevant jurisdiction that has adopted the CRS. In order for the Manager and the Fund to comply with their obligations under the IGA and CRS, the Subscriber The Subscriber's Agent must complete the appropriate Declaration of Tax Residence Form for the purposes of Part XVIII [FATCA] and Part XIX [CRS] of the Income Tax Act (Canada) and will provide updated Forms upon reasonable request by the Manager, unless Schedule “C” has been completed by the Subscriber and the Subscriber has agreed to discharge such obligation. The Subscriber must immediately notify promptly inform the Manager if any of the information provided changes and may request information from the Manager on its forms changeswhether their account information has been reported to the CRA and what information was provided. The Subscriber acknowledges that if the Manager is required to report information to the CRA in connection with the Subscriber’s investment in the a Fund, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise. Furthermore the Subscriber acknowledges that it remains solely responsible for determining the tax status of the Investor and to comply with all related and applicable CRA due diligence and reporting requirements in that regard. Privacy Policy Attached as Schedule E hereto is a copy of the Manager’s Privacy Policy. By signing this Subscription Agreement, the Subscriber consents to the collection, use and disclosure of his or her personal information in accordance with such policy.

Foreign Tax Reporting. In accordance with the Intergovernmental Agreement between Canada and the United States for the enhanced exchange of tax information under the Canada-U.S. Tax Convention (the “IGA”) and related Canadian legislation and guidance, and as required under the U.S. Foreign Account Tax Compliance Act (“FATCA”), the Fund, the Manager and/or registered dealers are required to report certain information with respect to Subscribers who are U.S. residents and U.S. citizens (including U.S. citizens who are residents or citizens of Canada), and certain other “U.S. Persons” as defined under the IGA, to the Canada Revenue Agency (“CRA”). The CRA is then expected to exchange the information with the U.S. Internal Revenue Service (“IRS”) pursuant to the provisions of the IGA. In addition, to meet the objectives of the Organization for Economic Co-operation and Development Common Reporting Standard (the “CRS”), the Fund, the Manager and/or the registered dealers are required under Canadian legislation to identify and report to the CRA details and certain financial information relating to unitholders in the Fund who are residents in a country outside of Canada and the U.S. which has adopted the CRS. It is expected that the CRA will then provide that information to the tax authorities of the relevant jurisdiction that has adopted the CRS. In order for the Manager and the Fund to comply with their obligations under the IGA and CRS, the Subscriber all Subscribers must complete provide the appropriate Declaration of Tax Residence Form for the purposes of Part XVIII [FATCA] and Part XIX [CRSCommon Reporting Standard] of the Income Tax Act (Canada) ), and will provide updated Forms upon reasonable request by the Manager, unless Schedule “CB” has been completed by the Subscriber and the Subscriber Subscriber’s Agent has agreed to discharge such obligationobligations by checking the “Yes” box in Schedule “B”. The Subscriber must immediately notify the Manager if any information on its forms Forms changes. The Subscriber acknowledges that if the Manager is required to report information to the CRA in connection with the Subscriber’s investment in the Fund, such report shall not be treated as a breach of any restriction upon the disclosure of information that may be imposed by Canadian law or otherwise. Privacy Policy Attached as Schedule “J” hereto is a copy of the Manager’s Privacy Policy. By signing this Subscription Agreement, the Subscriber consents to the collection, use and disclosure of his or her personal information in accordance with such policy.