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 proposed legislation and guidance, and as required under the U.S. Foreign Account Tax Compliance Act (“FATCA”), the Manager 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 will then exchange the information with the U.S. Internal Revenue Service (“IRS”) pursuant to the provisions of the Canada-U.S. Tax Convention. In order for the Manager and the Fund to comply with their obligations under the IGA, unless the Dealer has agreed to discharge such obligations in Schedule “B”, all Subscribers must complete Appendix “1” and must immediately notify the Manager if any information provided on Appendix “1” changes.