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2007 Distributions
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For Canadian Residents (click here for 2007 tax information) |
Unless otherwise indicated, all dividends were designated as eligible dividends
as defined in subsection 89(1) of the Income Tax Act (Canada).
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Date of Distribution
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Distribution Paid
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January 15, 2008 |
C$0.1625 |
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December 17, 2007 |
C$0.1625 |
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November 15, 2007 |
C$0.2708 |
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October 15, 2007 |
C$0.2708 |
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September 17, 2007 |
C$0.2708 |
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August 15, 2007 |
C$0.2708 |
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July 16, 2007 |
C$0.2708 |
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June 15, 2007 |
C$0.2708 |
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May 15, 2007 |
C$0.2708 |
| April 15, 2007
|
C$0.2708
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| March 15, 2007
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C$0.2708
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| February 15, 2007 | C$0.2708 |
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For U.S. persons (click here for 2007 tax information)
Additional Information Concerning the December 2007 Internal Reorganization
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Date of Distribution
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Total Amount
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Other Income
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Interest Income |
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January 15, 2008 * |
C$0.1625 |
C$0.1625 |
C$0.00 |
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December 17, 2007 |
C$0.1625 |
C$0.0087 |
C$0.1538 |
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November 15, 2007 |
C$0.2708 |
C$0.1208 |
C$0.1500 |
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October 15, 2007 |
C$0.2708 |
C$0.1173 |
C$0.1535 |
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September 17, 2007 |
C$0.2708 |
C$0.1086 |
C$0.1622 |
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August 15, 2007 |
C$0.2708 |
C$0.1077 |
C$0.1631 |
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July 16, 2007 |
C$0.2708 |
C$0.1082 |
C$0.1626 |
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June 15, 2007 |
C$0.2708 |
C$0.1061 |
C$0.1647 |
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May 15, 2007 |
C$0.2708 |
C$0.1024 |
C$0.1684 |
| April 15, 2007
|
C$0.2708
|
C$0.0994
|
C$0.1714 |
| March 15, 2007
|
C$0.2708
|
C$0.0987
|
C$0.1721 |
| February 15, 2007 | C$0.2708 | C$0.0972 | C$0.1736 |
* Distribution not included in 2007 tax year - to be included in 2008 tax
year. |
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2007 Tax Information
For Canadian residents only
The following information is intended to assist unitholders of Cinram International
Income Fund (the “Fund”) in the preparation of their 2007 income tax returns and
does not constitute legal or tax advice. Unitholders are advised to consult with
a tax advisor as residency and other circumstances may vary.
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1. Trust units
held in a registered account |
If you held your Cinram International
Income Fund units in a registered account (RRSP, RRIF, RESP or DPSP) and
received distributions during 2007, no amounts are
to be reported on your 2007 tax return.
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2. Trust units held in a non-registered account |
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If you held your units in a non-registered account and received distributions
during 2007, you should have received a T3 slip reporting all of the cash distributions as a taxable dividend received on a share of the capital stock of a taxable Canadian corporation for Canadian income tax purposes.
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A portion of these same distributions may have been subjected to 30% U.S. withholding tax if you failed to submit a valid form W-8 BEN to your broker/administrator.
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If you did not submit a valid W-8 BEN form, the U.S. tax withheld will be reported
on form 1042-S.
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The amount of gross income reported in Box 2 of this form does not represent additional
cash distributions paid during the year. It represents the portion of the distributions
which are subject to U.S. withholding, and does not need to be reported in the Canadian
income tax returns filed by Canadian residents as additional income for tax purposes.
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With respect to the amount of U.S. tax withheld and disclosed in Box 7 of the form
1042-S, as a Canadian resident, you may be able to either:
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- recover the tax by filing a U.S. income tax return on form 1040NR (in the case of
an individual taxpayer) or form
1120 F (in the case of a corporate taxpayer); or
- claim the amount on the taxpayer’s
Canadian income tax return as foreign non-business income tax paid in the year,
deductible pursuant to subsection 20(12) of the Income Tax Act (Canada).
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For U.S. persons only |
The following information is intended to assist unitholders of Cinram International
Income Fund (the “Fund”) in the preparation of their 2007 income tax returns and
does not constitute legal or tax advice. Unitholders are advised to consult with
a tax advisor as residency and other circumstances may vary.
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If you were a U.S. person that held units of Cinram International Income Fund and
received distributions in 2007, you should have received the following tax slips: |
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The entire distribution was subject to Canadian withholding tax at a 15% rate when
distributed to U.S. persons. If the distributions you received were subject to Canadian
withholding tax, you may be able to claim a foreign tax credit against the tax payable
on such distributions in the jurisdiction in which you file your tax return.
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Based on the characterization of the Fund for U.S. tax purposes, a portion of the
distributions may have been subjected to U.S. backup withholding tax at the 28%
statutory rate if you failed to submit a valid form W-9 to your broker /administrator.
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Additional 2007 tax information for U.S. resident taxpayers |
To provide Cinram International Income Fund
(“CIIF”) with a portion of the capital to repurchase units under its 2007 Normal
Course Issuer Bid, distributions were paid from a lower tier subsidiary, Cinram
International Inc. (“CII”), and then through several affiliated companies to CIIF.
These distributions occurred from August to November 2007. For U.S. taxation purposes,
each of the intermediate affiliates is either a disregarded entity or a partnership,
resulting in these entities acting as flow through conduits when receiving income
or capital receipts. This results in each unitholder of CIIF receiving a pro-rata
share of the distributions paid by CII. As CII has determined that it had neither
current nor accumulated earnings and profits as at the close of its tax year ended
December 31, 2007, these distributions have been treated as a “non-dividend distributions”
in Box 3 of form 1099-DIV.
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U.S. tax treatment of the distribution paid on January 15, 2008 |
The 1099-DIV forms prepared by CIIF’s transfer
agent, Computershare, for registered U.S. resident taxpayers will not include the
distribution paid on January 15, 2008. The transfer agent is following Internal
Revenue Service Revenue Ruling 62-131, which stipulates that a distribution is tested
for dividend treatment on the date of the actual distribution payment rather than
at the declaration date. Accordingly, a subsequent 1099-DIV form reflecting the
January 15, 2008, distribution will be prepared and issued in 2009 for the 2008
taxation year.
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For foreign residents (non-U.S.) only |
The following information is intended to assist unitholders of Cinram International
Income Fund (the “Fund”) in the preparation of their 2007 income tax returns and
does not constitute legal or tax advice. Unitholders are advised to consult with
a tax advisor as residency and other circumstances may vary.
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If you were a foreign resident (non-U.S.) that held units of Cinram International
Income Fund and received distribution in 2007, the entire distribution was subject
to Canadian withholding tax at the rate applicable to you as a foreign resident
holder, when distributed. This may be a 25% rate, or lower, if you are a resident
of a treaty country. If the distributions you received were subject to Canadian
withholding tax, you may be able to claim a foreign tax credit against the tax payable
on such distributions in the jurisdiction in which you file your tax return.
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Based on the characterization of the Fund for U.S. tax purposes, a portion of the
distributions may have constituted U.S. source interest income which is subject
to U.S. withholding tax at the 30% statutory rate. If you were a non-U.S. person,
you may have been eligible for the portfolio interest exemption from U.S. withholding
tax. You may have received this exemption if you submitted a valid Form W-8BEN to
your broker/administrator.
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**For unitholders
that did not file W8 or W9 exemption forms. |
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