The Fund does not expect to pay distributions. Consequently, the Fund does not expect to issue T3 slips in most years, except in the instance of a capital gains dividend paid by the Fund to ensure the Fund is not taxed. In this circumstance, capital gains tax will be incurred by the shareholder in the year of the dividend payment.

Warrants

If a warrant is sold prior to expiry, warrant holders will be subject to tax on any capital gains realized on the disposition. If a warrant is exercised, this will not constitute a disposition, so no tax is incurred until disposition of the equity shares, at which point shareholders will be subject to tax on any capital gains realized on the disposition. Unexercised warrants will result in a capital loss equal to the adjusted cost base of the warrant to the shareholder.

For units acquired pursuant to the initial public offering, a reasonable allocation of the $10.00 purchase price, acquired by cash or by exchange offer, between the equity share and the one-half warrant must be made for tax purposes. The Fund has allocated $0.50 of the purchase price to each one-half warrant though the Canada Revenue Agency may not agree with such allocation.