--_000_YT2PR01MB96192CB007C3763E4F97F681A71FAYT2PR01MB9619CANP_ Content-Transfer-Encoding: quoted-printable Content-Type: text/plain; charset="iso-8859-1" HI Brian, I just wanted to follow up on the below so that we can get the billings run= ning. Thanks! Renee Ip Senior Manager, Indirect Tax KPMG LLP Vaughan Metropolitan Centre 100 New Park Place, Suite 1400 Vaughan, ON L4K 0J3 Tel: 416-228-7027 Fax: 905-265-6390 Reneeip@kpmg.ca Any advice herein is based on the facts provided to us and on current tax l= aw including judicial and administrative interpretation. Tax law is subject= to continual change, at times on a retroactive basis and may result in inc= remental taxes, interest or penalties. Should the facts provided to us be i= ncorrect or incomplete or should the law or its interpretation change, our = advice may be inappropriate. We are not responsible for updating our advice= for changes in law or interpretation after the date hereof. Qu=E9bec announced through its November 10, 2017 economic plan that it inte= nds to introduce legislation that will prohibit a taxpayer who has carried = out a transaction, or series of transactions, subject to a Revenu Qu=E9bec = final assessment based on the general anti-avoidance rule from being able t= o obtain authorization from the Autorit=E9 des march=E9s financiers (AMF) t= o bid for or obtain public contracts. The taxpayer will be listed in the R= egister of Enterprises Ineligible for Public Contracts. Our advice is limited to the conclusions specifically set forth herein and = KPMG expresses no opinion with respect to any other federal, provincial or = foreign tax or legal aspect of the transactions described herein. It should= be noted that the Canada Revenue Agency and/or the relevant provincial tax= authority and/or a foreign tax authority and/or any other governmental tax= authority (collectively a Tax or Revenue Authority) could take a different= position with respect to these transactions in which case it may be necess= ary for you to defend this position on appeal from an assessment or litigat= e the dispute before the courts, including one or more appellate courts, in= order for our conclusions to prevail. If a settlement were reached with a= Tax or Revenue Authority or if such appeal and litigation were not, or wer= e not entirely, successful, the result would likely be different from the v= iews we express herein. Unless expressly provided for, KPMG's services do = not include representing Client in the event of a challenge by a Tax or Rev= enue Authority or litigation before any court. KPMG's advice is for the sole use of KPMG's client. The advice is based on= the specific facts and circumstances and the scope of KPMG's engagement an= d is not intended to be relied upon by any other person. KPMG disclaims an= y responsibility or liability for any reliance that any person other than t= he client may place on this advice. From: Ip, Renee Sent: Thursday, August 17, 2023 8:26 PM To: brian.fial