Hedge Fund Subscription Procedure (Page 23 of 23) in pdf

entity with a financial account. Under the Canadian IGA, the CRA would exchange this information with the U.S. Internal Revenue Service

(IRS). As a result, Canadian financial institutions are required to ask for the tax status of an entity account holder and certain information on any

controlling persons of the entity who are considered U.S. persons. Please advise AGF Investments Inc. immediately if the entity or any

controlling persons have a change in circumstances of the information provided in the Entity Tax Self-Certification form.

Requirement to provide Taxpayer Identiﬁcation Number(s) (TIN)

Under the Income Tax Act (Canada), the CRA may impose a penalty if you fail to provide the Canadian financial institution with the

requested Social Insurance Number (SIN), Business Number (BN) or the U.S. TIN, as applicable. If you are a (specified) U.S. person and

you do not have a U.S. TIN, penalties will not be assessed if an application for the assignment of the U.S. TIN is made within 90 days of

the request and provided to AGF Investments Inc. within 15 days of receipt.

Will the account be reported?

In general, an account will be reported if the account holder is a specified U.S. person, a Passive NFFE with U.S. Person(s) as controlling

person(s) or a NPFI. In addition, an account may also be reported if the account holder fails to provide the necessary documentation as requested

by AGF Investments Inc., even though the account holder may not be a specified U.S. person, a Passive NFFE with U.S. Person(s) as a

controlling person(s) or a NPFI.

To the extent an account is reportable, under the Canadian IGA, the financial institution will report the account information to the CRA. The

CRA may then provide this information to the IRS in accordance with the provisions of the Canada-U.S. Tax Convention.

Where can I obtain further information?

For further information, please visit the CRA website at or the IRS website at

Footnotes

A controlling person may include:

•

Any shareholder or partner who directly or indirectly owns 25% or more of a corporation or a partnership.

•

Any beneficiary (regardless of % of ownership interest), trustee or settlor of a trust.

Agreement Between the Government of the United States of America and the Government of Canada to Improve International Tax Compliance through Enhanced

Exchange of Information under the Convention Between the United States of America and Canada with Respect to Taxes on Income and on Capital.

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Hedge Fund Subscription Procedure Page 23

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