INSTRUCTIONS FOR DECLARATION OF TAX RESIDENCE FOR ENTITIES (Canada Revenue Agency (“CRA”) Form RC521 E)

Form Completion Guide – RBC Direct Investing Clients

Definitions and Common Reporting Standard (“CRS”) Entity Classifications are located in the General Information section of the CRA Form RC521. Refer to page 8 for the links to CRS Guidance and CRA Forms. Section 1 – Identification of account holder Complete information of the entity under this section.

Legal name of the entity Enter full Legal Name of the Entity. Do not abbreviate any portion of name.

Jurisdiction of incorporation or organization Enter full name of Country. Do not abbreviate name of Country. (Do not enter Province.)

Policy/account number assigned by the financial institution Enter your RBC Direct Investing Account Number. Mandatory for existing clients.

Permanent residence address Enter Permanent residence address of Entity (physical location or registered address indicated on the organizational documents).

Mailing address (only if different from permanent residence address)

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------------------------------------------------------------------------------------------------------------------------------- Section 2 – Declaration of tax residence: Tick all of the options that apply to the Entity.

The entity is a tax resident of Canada. If Entity is a tax resident of Canada only, tick the first box. Note: Business number and Trust account number of an Entity are CRS Documentation requirements as outlined by the Canada Revenue Agency (CRA). If Entity is a Trust, input the CRA Trust Account Number in Trust account number box. If other type of Entity, such as a Corporation, input Entity’s CRA Business Number. Do not enter the Entity’s Provincial registration number.

The entity is a tax resident of a jurisdiction other than Canada. If Entity is a tax resident of a jurisdiction or country other than Canada, tick the second box. Enter name of Country under ’Jurisdiction of tax residence’ field. Enter the Entity’s Taxpayer Identification Number (TIN). If Entity does not have a TIN, enter applicable Reason code 1, 2 or 3 in field, ‘If the entity does not have a TIN, choose reason 1, 2, or 3.’. RE REASON 3: If Reason 3 is selected, CRA requires the Specific Reason why the Entity did not provide the TIN. Provide the Specific Reason on a separate attachment. Or, if there is enough space, the explanation can be completed beside Reason 3 in the box on the form.

If the Entity is a tax resident of both Canada and other country(s), tick both boxes. Complete:

• CRA Business Number/Trust Account Number • Foreign Country(s) • Taxpayer Identification Number(s) and/or Reason Code(s) for the other

Country(s)

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------------------------------------------------------------------------------------------------------------------------------- Section 3 – Entity Classification. NB: Review Sections 3.1, 3.2 and 3.3. Complete appropriate Entity Classification.

Complete and append Annex - Controlling Persons if Entity Classification is Managed Entity in a non-participating jurisdiction/country or Passive Non-Financial Entity (Passive NFE).

Section 3.1 - Is the entity a financial institution? If the Entity is not a Financial Institution, tick No and go to Section 3.3. If the Entity is a Financial Institution, tick Yes, complete Global Intermediary Identification Number (GIIN) and go to section 3.2. If the Entity is a Financial Institution, and does not have a GIIN, the reason why it does not have a GIIN must be provided on the specified reason line.

Section 3.2 - Does the financial institution meet all of these criteria? If the Financial Institution does not meet all the criteria listed, tick No and complete Section 4 (Certification). If the Financial Institution meets the listed criteria, tick Yes, complete Controlling Persons* of the Entity in the Annex and complete Section 4 (Certification). Alternatively, each additional Controlling Person can complete Declaration of Tax Residence for Individuals – Part XIX of the Income Tax Act (CRA Form RC520). Ensure Type of controlling person is completed in the box on page 2.

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Section 3.3 Tick the option that best describes the entity. (Tick only 1 box.) If Entity is a Passive Non-financial Entity (Passive NFE)—i.e. the last box is ticked under this section, complete Annex – Controlling Persons.

• Information for two (2) Controlling Persons can be completed on one (1) Annex – Controlling Persons.

• If there are more than two (2) Controlling Persons, complete and print additional Annex – Controlling Persons.

NOTE:

• CRA Form RC520 can also be used for each Controlling Person of the Entity.

• Ensure CRA Form RC520 is signed by the Individual—i.e. the Controlling Person, and the Type of Controlling Person is completed in the box on page 2 of the form.

See information regarding Controlling Persons* on page 7 of this guide. Continue to Section 4 – Certification

SECTION 3.3 - ENTITY CLASSIFICATION GRID

Definition of ACTIVE NFE and PASSIVE NFE are within Chapter 4 – Entity classifications under the Guidance on the Common Reporting Standard Part XIX of the Income Tax Act https://www.canada.ca/content/dam/cra-arc/migration/cra-arc/tx/nnrsdnts/nhncdrprtng/crs/gdnc-eng.pdf

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Section 4 – Certification The Certification must be completed by an authorized representative or officer of the Entity:

• Trusts - Trustee (as required based on the Trust Agreement/Document).

• Corporations - a person who is appointed on the Resolution to sign on behalf of the Entity.

• Other Non-Corporate Entities, such as Partnerships - a person who is appointed on the Resolution to sign on behalf of the Entity.

•

If Yes was ticked for Section 3.2 or if Passive Non-financial Entity ticked under Section 3.3, details of all Controlling Persons of the Entity are required. Append the Annex(s) – Controlling persons and/or completed CRA Form(s) RC520, for each Controlling Persons when submitting. See information regarding Controlling Persons* on page 7 of this Guide.

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Annex - Controlling Persons Details of all Controlling Persons* of the Entity are required for the following: • Yes ticked under Section 3.2 • Passive Non-financial Entity ticked under Section

3.3 If the Controlling Person does not have a TIN in a Country, and Reason 3 is selected, CRA requires the Specific Reason why the Individual did not provide the TIN. Provide the Specific Reason on a separate attachment. Or, if there is enough space, the explanation can be completed beside Reason 3 in the box on the form. If the Controlling Person (Individual) only has a tax residence in Canada, the Canadian Social Insurance Number (SIN) is not mandatory.

Annex - Controlling Persons Information for two (2) Controlling Persons can be completed on one (1) Annex – Controlling Persons. If there are more than two (2) Controlling Persons, complete and print additional Annex – Controlling Persons. The noted fields for Controlling Person 1 would be the same fields required to be completed for Controlling Person 2 and all other Controlling Persons being completed on additional Annex – Controlling Persons. Note that CRA Form RC520 can also be used for each Controlling Person of the Entity. However, ensure CRA Form RC520 is signed by the Individual—i.e. the Controlling Person, and the Type of Controlling Person is completed in the box on page 2.

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------------------------------------------------------------------------------------------------------------------------------- *Controlling Persons Information “Controlling Persons” of an Entity are the natural persons (Individuals) who exercise direct or indirect control over an entity. Generally, whether a person exercises control over an entity is determined in a way similar to how beneficial owners are identified for Canada’s Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). It is important to note that for Entities other than Trusts, a Controlling Person’s percentage of ownership for clients of Canadian Financial Institutions that are regulated by the Investment Industry Regulatory Organization of Canada (IIROC) is 10% or more; the Controlling Person’s percentage ownership for clients of other Canadian Financial Institutions (including banks and trust companies) is 25%. Generally, whether an individual has control over an entity is determined by how beneficial owners are identified in the PCMLTFA, as well as the ownership thresholds set by Canadian financial regulatory authorities. (IIROC member firms, such as RBC Direct Investing are required to identify all Individuals who beneficially own, direct or control 10% or more of corporate or other non-corporate accounts, whether directly or indirectly.) For a Corporation, an Individual is considered to be controlling if they directly or indirectly own or control 25% or more of the corporation. If no Individual is identified as controlling the Corporation, a director or senior official of the Corporation will be treated as the Controlling Person. For a Trust, the Controlling Persons include its Settlors, Trustees, Protectors (if any), Beneficiaries or Class of Beneficiaries, and any other Individuals having ultimate effective control over the Trust.

Descriptions of Types of Controlling Persons Refer to page 4 of the General Information of the CRA Form RC521 for full definition and descriptions of Controlling Persons.

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-------------------------------------------------------------------------------------------------------------------------- Internet Links for more Information

Organization for Economic Co-operation and Development (OCDE) - Common Reporting Standard:

http://www.oecd.org/tax/automatic-exchange/common-reporting-standard/standard-for-automatic-exchange-of-financial-account-information-for-tax-matters-9789264216525-en.htm Canada Revenue Agency (CRA) Guidance on the Common Reporting Standard – Part XIX of the Income Tax Act: https://www.canada.ca/content/dam/cra-arc/migration/cra-arc/tx/nnrsdnts/nhncdrprtng/crs/gdnc-eng.pdf

Included in the Guidance are details and definitions regarding: • Financial Institution • Non-financial Entity (NFE) • Active Non-financial Entity (Active NFE) • Passive Non-financial Entity (Passive NFE) • Controlling Persons • Managed Account

Canada Revenue Agency (CRA) - Information for entities holding accounts with Canadian financial institutions:

http://www.cra-arc.gc.ca/tx/nnrsdnts/nhncdrprtng/ntts-eng.html Canada Revenue Agency (CRA) Declaration of Tax Residence Forms:

Form RC521 E (Declaration of Tax Residence for Entities -- Part XIX of the Income Tax Act and Instructions) https://www.canada.ca/content/dam/cra-arc/formspubs/pbg/rc521/rc521-fill-18e.pdf Form RC520 E (Declaration of Tax Residence for Individuals – Part XIX of the Income Tax Act and Instructions) https://www.canada.ca/content/dam/cra-arc/formspubs/pbg/rc520/rc520-fill-18e.pdf

Tax residency information for the Declaration of Tax Residence Forms, see Residency of a corporation under the following link:

http://www.cra-arc.gc.ca/tx/nnrsdnts/bsnss/bs-rs-eng.html