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Section C - Direct Subscribers

The reduction in CEE renounced to subscribers that are corporations will lead to a reassessment of their taxation year that includes the effective date of renunciation and/or one or more subsequent taxation years. The reduction in CEE renounced to subscribers that are corporations will lead to a reassessment of their taxation year that includes the effective date of renunciation and/or one or more subsequent taxation years.

When you receive a Notice of Reassessment from the CRA, you should file a Notice of Objection within 90 days of the date noted on the Notice of Reassessment. We expect that your appeal will be held in abeyance pending the outcome of our dispute with the CRA relating to the CEE that was denied.

The appeals process will take some time to resolve, so we encourage you to pay the accrued tax and interest noted on the Notice of Reassessment – this will stop interest from accumulating on the outstanding balance during the appeals process.

If Lake Shore Gold Corp. is partially or entirely successful in its dispute with the CRA and you file a Notice of Objection within the 90 day window, you should receive: 

(i) a consequential Notice of Reassessment restoring all or a portion of the CEE renounced effective December 31, 2014;

(ii) a refund of some or all of the tax and interest you paid in connection with the original Notice of Reassessment; and

(iii) an additional payment of interest if you paid the original Notice of Reassessment.

Subscribers who do not file a Notice of Objection within the 90 day window will not be entitled to receive a consequential reassessment, refund or interest payment even if Lake Shore Gold Corp. is partially or entirely successful in its dispute with the CRA.  In addition, such subscribers will not be entitled to an indemnity for taxes paid or payable under the original Notice of Reassessment.

Subscribers may object by filing a Notice of Objection in a T400A Form – the link to that form is here. Please fill out the T400A Form with your own personal information according to the instructions. In the box where it asks you to provide the issues, reasons, and all relevant facts for your objection, please include the following language: 

[Name of corporation] hereby objects to the amounts assessed, penalties and interest and any consequential adjustments in their entirety.  Further facts, reasons and supporting documentation will be provided to an Appeals Officer, as necessary, once one is assigned.  

[Name of corporation] requests that this Notice of Objection be assigned to the same Appeals Officer as is handling the related Notices of Objection being filed by Lake Shore Gold Corp. (BN 12556 4005) for its 2014 and 2015 taxation years (the “Lake Shore Objections”).  These Objections all relate to the tax treatment of CEE arising out of the same facts.  

[Name of corporation] also requests that this Notice of Objection be held in abeyance pending resolution of the Lake Shore Objections as it understands that the result of the Lake Shore Objections will impact its dispute.

You should include a cover letter with your T400A Form – a link to a sample cover letter is here. If you file a Notice of Objection as instructed, we expect the CRA will make the necessary consequential reassessments of your income tax returns if Lake Shore Gold Corp. is partially or entirely successful with its dispute. The second page of the T400A Form explains how to submit your Notice of Objection to the CRA.