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Tax Treatment Of Unitholder Distributions

Based on the Fund’s analysis and external advice on the Tax Fairness Plan, the Fund believes that, commencing in 2011, the income portion of distributions to individuals holding their units outside a tax deferred account will be treated the same as taxable dividends from a Canadian corporation commencing in 2011. Returns of capital by the Fund to its unitholders should not be impacted by the Tax Fairness Plan. Since this is only a general summary and unitholders’ individual circumstances will vary, it is not intended, nor should it be treated, as a representation of the income tax consequences to any particular unitholder or as tax or legal advice.

Unitholders should consult their own tax advisors to clarify the impact of the Tax Fairness Plan on their individual circumstances.