This summary does not address the possible application of the rules in the Tax Act related to hybrid mismatch arrangement ("the Hybrid Mismatch Rules") to a Note Holder (i) that disposes of a note to a person or entity with which it does not deal at arm's length or to an entity that is a "specified entity" (as defined in the Hybrid Mismatch Rules) with respect to the Note Holder or in respect of which the Note Holder is a "specified entity", (ii) that disposes of a note under, or in connection with, a "structured arrangement" (as defined in the Hybrid Mismatch Rules), or (iii) in respect of which BFI is a "specified entity". Such Note Holders should consult their own tax advisors.

This summary is of a general nature only and is not intended to be, nor should it be construed to be, legal or tax advice to any particular Note Holder and no representations with respect to the income tax consequences to any particular Note Holder are made. This summary is not exhaustive of all Canadian federal income tax considerations. Accordingly, prospective purchasers should consult their own tax advisors for advice with respect to the tax consequences to them of acquiring, holding and disposing of the notes, including the application and effect of the income and other tax laws of any country, province, territory, state or local tax authority.