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Depat\ment of Justice
Canada

M i nist~re.de

Ia Justlce

Canada

Tax Law Services
900 - 840 Howe Street
Vanco.uver, British Columbia
V6Z289

Phone: (604) 666· 5443
Fal<:
(604) 666-1462

October 18, 2012

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BY FAX

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3n"'Bl\y·'al~ St1ite 46oo
Bay Adelaide Centre

Toronto, ON M5H 2S5

Attention: Bill Thomas, CEO and Senior Partnet·
Oear Sir:

Re:

.Notice to freserve Docun'ients
Our File No. 3-276734

We act as counsel for the Minister ofNational Revenue. The Minister intends to make an
ex parte application to the Federal Court for an order under subsection 231.2(3) of the
Income Tax,Act ("Act"), authorizing her to issue to .KPMO LLP requireJ;Dents to provide
informatioh and documents. under subsection 231.2(1) of the Act. The information and
documents sought pertain to KPMG clients who have participated in the tax and estate
planning product ofKPMG known as Off.<rhore Company, including the names and
addresses of such clients and all tax pla1ming documentation and correspondence relating
to such clients. The irrronnation and.documents sought are :fot the per'iods from January
1, 1999 to December 31, 2011.

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We understand that you had a conversation on June 28, 2012 with Russell Lyon of the
Canada.Rever1ue Agency with respect to this matter. We reiterate Mr. Lyon's notice that.
KPMG preserve the information and docume:nts described above. This includes a
suspension oli all document destruction policies with respect to S\.lCh information and
documents.
Thank you for yow· cooperation. )?lease do not hesitate to contact ine if you have any
questions.

Yours tl'uly,

ryvv.

Neva Beckie
Senim' Com1sel
Tax Law Services
c: client