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As discussed in our prior client advisory Significant Proposed HST Changes for Funds and Their Managers, on May 19, 2010, the Department of Finance ("Finance") released a backgrounder (the "May Release") describing proposed rules (the "Proposed Rules") for determining the ultimate HST liability of investment plans (including registered pension plans, mutual fund trusts, mutual fund corporations, and unit trusts) and segregated funds of insurers (collectively "Funds"
