This summary is not applicable to a Note Holder (i) that is a "financial institution" (as defined in the Tax Act for purposes of the "mark-to-market" property rules), (ii) an interest in which is a "tax shelter investment" (as defined in the Tax Act), (iii) that has elected to report its "Canadian tax results" (as defined in the Tax Act) in a functional currency in accordance with the provisions of the Tax Act or (iv) that enters into or will enter into a "derivative forward agreement" (as defined in the Tax Act) in respect of the notes. Such Note Holders should consult their own tax advisors having regard to their particular circumstances. This summary does not address the split income rules in section 120.4 of the Tax Act. Note Holders should consult their own tax advisors in this regard. In addition, this summary does not address the deductibility of interest by a Note Holder who has borrowed money or otherwise incurred debt in connection with the acquisition of the notes. Note Holders should consult their own tax advisors in that regard.