Rainer Nowak MEMBERS Sr. Chief Alberta Investment Management Corporation Allied Properties REIT General Operations & Borders Issues Artis REIT Aspen Properties Ltd. Finance Canada Avison Young 140 O’Connor Street Baybridge Seniors Housing Inc. Bentall Kennedy Group Ottawa, Ontario K1A 0G5 BMO Capital Markets Real Estate Inc. Boardwalk REIT Brookfield Financial Real Estate Group September 28th, 2012 Brookfield Office Properties Brookfield Real Estate Opportunity Fund Build Toronto Inc. Cadillac Fairview Corporation Ltd., The Re: GST/HST Impacts on Canadian REITs Calloway REIT Canderel CAPREIT CB Richard Ellis Limited In response to a consultation on financial institution rules, REALpac would like to CIBC World Markets Inc. Colliers International. Inc. make the following issues known to Finance: Cominar REIT CREIT (Canadian REIT) Crombie REIT Cushman & Wakefield Ltd. It was recently brought to our attention that the GST/HST charged on the costs Dorsay Development Corp. related to capital raises and corporate transactions are not permitted to be claimed as Dundee REIT EPIC Realty Partners Inc. Input Tax Credits (“ITC”) on the REITs GST return (S. 185). For many Canadian Fengate Capital Management Ltd. Fiera Properties REITs that are in substantial growth mode, raising capital, be it debt or equity, is First Capital Realty Inc. First National Financial LP integral for the REIT to achieve its mandate. However, the inability to claim the ITC Gazit America Inc. on GST/HST charged on costs related to capital growth means that REIT “all in” GE Capital Real Estate Granite Real Estate costs are more expensive than their real estate counterparts structured as a Greystone Managed Investments Inc. Grosvenor Americas Limited corporation. In the end, this creates an uncompetitive playing field, is in essence an GT Canada Medical Properties REIT additional tax on the REITs for being structured as a trust, and can significantly erode GWL Realty Advisors Inc. H & R REIT unit holder value. Homestead Land Holdings Limited IGRI Inc. Infrastructure Ontario Ivanhoe Cambridge We would be pleased to meet with you and your staff in person to discuss this issue. KeyREIT Please provide us with some times that will work, and we’d be happy to arrange our Killam Properties Inc. M3 Capital Partners schedules accordingly. In the mean time, please feel free to contact Paul Morse at Macquarie Capital Markets Canada, Ltd. Manulife Financial [email protected] or (416) 642-2700 ext. 225 or Ryan J. Eickmeier at MCAN Mortgage Corporation [email protected] or (416) 642-2700 ext. 224. Melcor Developments Ltd. Menkes Development Ltd. Minto Group, The Morguard Corporation Regards, Morguard Investments Limited Morguard REIT Mortgage Fund Three National Bank Financial Northern Property REIT NorthWest Healthcare Properties REIT OPTrust Oxford Properties Group Inc. Parkbridge Lifestyle Communities Inc.. Partners REIT Paul Morse Ryan J. Eickmeier PIRET Plazacorp Retail Properties Limited. Chief Executive Officer Manager, Government Relations & Primaris Retail REIT Policy Public Storage Canadian Properties Raymond James Ltd. RBC Capital Markets Real Estate Group Retrocom Mid-Market REIT RioCan REIT Scotia Capital Inc. Scotiabank SilverBirch Hotels & Resorts Skyline Standard Life Investments (Real Estate) Inc. Sun Life Assurance Company of Canada TD Securities Inc. Timbercreek Asset Management Inc. Triovest Realty Advisors Inc. .