Citation: 2008TCC257
Date: 20080520
Docket: 2007-1469(IT)I
BETWEEN:
JEAN-CLAUDE RICHARD, S/N PRODUITS
FORESTIERS J.C.R. ENR.,
Appellant,
and
HER MAJESTY THE QUEEN,
Respondent.
[OFFICIAL ENGLISH
TRANSLATION]
REASONS FOR JUDGMENT
Bédard J.
[1]
In computing his income
for the 2002 and 2003 taxation years, the Appellant claimed losses from the
operation of a logging business in the amounts of $43,292 and $37,062,
respectively. By notice of reassessments dated April 18, 2005, the Minister of
National Revenue ("the Minister") made the following changes in
computing the Appellant's income for the taxation years in issue:
(a)
the Minister's position is that the Appellant is
carrying on a farming business with the reasonable expectation of profit, but
whose chief source of income is not farming or a combination of farming and
some other source of income;
(b)
the Minister allowed $8,750 per year as
deductible losses from a farming activity that is not the chief source of
income, and computed the limited farming losses that may be carried forward as
$34,542 and $28,312, respectively.
The Appellant has appealed from the income tax
reassessments made by the Minister for the 2002 and 2003 taxation years.
[2]
In making and
confirming the reassessments, the Minister assumed the same facts:
(a)
the Appellant has
worked for Hydro-Québec since 1981; (admitted)
(b)
the Appellant is a
lumberjack's son and worked in that occupation from 1969 to 1978; (admitted)
(c)
the Appellant and
Michèle Neveu have a blended family with three children:
(i)
Kathleen, born in
February 1982;
(ii)
Joanie, born in May
1987;
(iii)
Pierre-Olivier, born in
February 1993.
(admitted)
(d)
for the taxation years
in issue, the Appellant declared that he was carrying on business as sole
proprietor exploiting the following property or assets under the business name Produits
forestiers J.C.R. enr.:
(i)
woodlots in St-Michel-des-Saints
(4 lots);
(ii)
land adjacent to the
woodlots where four cottages were built;
(iii)
rental of 146 acres of
land from the Ministère des Ressources naturelles on which there is a sugar
maple bush, with the intention of producing maple syrup.
(admitted)
(e)
for the 2002 and 2003
taxation years, the Appellant worked four days a week as a Hydro-Québec
employee; (denied as worded)
(f)
during the 17-year
period (1987 to 2003), gross income from the alleged operation of a forest
business by the Appellant was higher than his income from employment on only
three occasions (1988, 1999 and 2000); (denied)
(g)
during that 17-year
period (1987 to 2003), the Appellant incurred annual losses in relation to the
alleged operation of a forest business, except in the 1999 taxation year; (denied)
(h)
for the taxation years
in issue, the losses incurred were practically equal to the Appellant's income
from employment; (no knowledge)
(i)
for the 2002 and 2003
taxation years, the auditor noted the breakdown of gross income from the
alleged operation of a forest business under the following various heads:
|
|
|
2002
|
2003
|
|
(i)
|
Subsidies
|
2,419
|
4,897
|
|
(ii)
|
syrup sales
|
5,345
|
3,722
|
|
(iii)
|
syrup by-product sales
|
649
|
1,656
|
|
(iv)
|
interest income (syrup)
|
122
|
1,146
|
|
(v)
|
gross rental income
|
2,000
|
2,000
|
|
(vi)
|
miscellaneous income
|
2,290
|
3,526
|
|
(vii)
|
timber sales
|
36
|
0
|
|
|
|
12,861
|
16,947
|
(admitted)
(j)
the Minister is of the
opinion that sylviculture and maple syrup production represent activities that
generate farming income rather than income from forest operations; (denied)
(k)
however, the Minister
is of the opinion that the Appellant is carrying on a farming business that is
not his chief source of income. (denied)
[3]
The Appellant, whose
credibility was not questioned, testified that:
(a)
during the years in
issue he was employed as a meter reader at Hydro-Québec;
(b)
his income from
employment during those years was $38,960 in 2002 and $40,000 in 2003;
(c)
he worked 130 days for
Hydro-Québec in 2003. It should be noted that the Appellant filed Hydro-Québec
records, as Exhibit A‑11, to corroborate his testimony on this point;
(d)
he spent 1,375 hours
working in his business in 2003, over 235 days;
(e)
during 2002, the days
spent working for Hydro-Québec and the days and hours spent on his business
were substantially the same as in 2003;
(f)
he has owned woodlots
since 1983. During the years in issue, he was the owner of about 176 hectares
of woodlots;
(g)
in 1986, he became a
forest producer within the meaning of section 120 of the Forest Act
(R.S.Q., c. F‑4.1). As a forest producer, the Appellant was eligible
for an assistance program for putting private woodlots into production. The
program offers financial and technical assistance for forest producers to carry
on logging activities in private forests. The purpose of the activities is to
protect and put into production any forest area registered under section 120 of
the Forest Act.
The activities covered by the assistance are:
(a)
preparation of forest
management plans;
(b)
technical assistance;
(c)
carrying out
sylviculture work;
(d)
supplying plants for
reforestation.
It should be noted that a producer must retain
a certified forestry consultant in order to obtain financial assistance and
have access to the professional and technical services needed for carrying out
the eligible work. The Appellant explained that in order to receive this
assistance, he had to retain a forestry engineering firm in 1986, Sylva
Croissance, the firm that has been advising him on the management of his
woodlots since that date;
(h)
the work he did under
the assistance program included the following:
(i) in 1987, he
prepared 1.5 hectares of land (scarifying, working, burning, etc.) and planted
7,500 spruce trees on the land;
(ii)
in 1988, he prepared
1.1 hectares of land and planted 2,700 spruce trees on it, and also maintained
the trees planted on 3 hectares;
(iii)
in 1998, he built 1.4
kilometres of forest roads and also improved 0.774 kilometres of forest roads;
(iv)
in 2000, he did
precommercial clearing on a two-hectare area. It should be noted that
commercial clearing is a logging activity whose purpose is to select and
segregate future young trees from their less promising neighbours, which are
interfering with their growth. This type of logging is called
"precommercial" because the logs cut are not large enough to be used
by industry. The logs are therefore left on site to enrich the soil as they decompose;
(v)
in 2000, he did
commercial clearing on a 0.7 hectare area. Commercial clearing is a
sylvicultural practice that involves removing some of the trees in the forest
in order to provide the trees chosen to remain in place with more light and space.
Commercial clearing is used to recover trees that would die sooner or later or
could not recovered;
(vi)
in 2000, he built 0.846 kilometres
of forest roads;
(vii)
in 2001, he did
precommercial clearing on a one hectare area;
(viii)
in 2003, he built 2.92 kilometres
of forest roads;
(i)
concurrently with the
subsidized work, he recovered (cut down and sawed up) timber for market. It
should be noted that the Appellant's income from the sale of timber to sawmills
and paper mills was as follows:
|
in 1988:
|
$19,054
|
|
in 1989:
|
$27,001
|
|
in 1990:
|
$5,558
|
|
in 1991:
|
$667
|
|
in 1992:
|
$4,636
|
|
in 1993:
|
$365
|
|
in 1994:
|
nil
|
|
in 1995:
|
$2,379
|
|
in 1996:
|
$1,454
|
|
in 1997:
|
$6,093
|
|
in 1998:
|
$15,267
|
|
in 1999:
|
$215,922
|
|
in 2000:
|
$77,247
|
|
in 2001:
|
$14,751
|
|
in 2002:
|
$36
|
|
in 2003:
|
nil
|
I would immediately note that the Appellant
was not able to state the number of hectares on which the logging work was done;
(j)
he did the sawing and
felling of the trees himself, except in 1999 and 2000, when he hired
subcontractors to do the work. The Appellant explained that he had recovered a
large quantity of wood for market in 1999 and 2000 in order to reduce his debt
from the purchase of a woodlot in 1999, which he was no longer able to pay;
(k)
he did not recover any
wood for market during the years in issue. The Appellant explained that he had
spent his time during those years building forest roads and repairing his
cottages in the woodlot he had purchased in 1999;
(l)
in 1998, he decided to
diversify his business and started producing maple syrup. For that purpose, he
rented a 146-acre lot from the Ministère des Ressources naturelles on which
there was a maple sugar bush and purchased equipment to produce maple syrup.
When the maple syrup market collapsed in 2000, he decided to sell his maple
syrup equipment and significantly reduce his maple syrup production while
waiting to find a buyer for his equipment. In 2002, he sold most of his maple
syrup equipment and operated part of the sugar bush on a small-scale basis
until 2005, when he completely abandoned the production of maple syrup.
[4]
The evidence also
establishes that:
(a)
during the 17-year
period from 1987 to 2003, the Appellant suffered annual losses in connection
with his business, except in 1999;
(b)
for the years from 1987
to 2003, the Appellant's gross business income, net business income and income
from employment were as follows:
|
|
Gross
business income
|
Net
business income
|
Income
from employment
|
Type of
income according to income tax return
|
|
1987
|
$1,548
|
-$3,384
|
$42,680
|
Farm income
|
|
1988
|
$25,864
|
-$8,979
|
$38,145
|
Business income
|
|
1989
|
$27,975
|
-$5,028
|
$27,766
|
Farm income
|
|
1990
|
$5,851
|
-$9,761
|
$45,658
|
Business income
|
|
1991
|
$870
|
-$11,017
|
$41,227
|
Business income
|
|
1992
|
$6,623
|
-$446
|
$39,880
|
Farm income
|
|
1993
|
$429
|
-$8,743
|
$40,136
|
Farm income
|
|
1994
|
$1,115
|
-$4,176
|
$45,456
|
Farm income
|
|
1995
|
$6,452
|
-$3,520
|
$38,763
|
Farm income
|
|
1996
|
$1,454
|
-$6,343
|
$40,446
|
Farm income
|
|
1997
|
$6,083
|
-$4,175
|
$42,277
|
Farm income
|
|
1998
|
$36,632
|
-$1,891
|
$39,728
|
Farm income
|
|
1999
|
$234,290
|
$9,824
|
$24,130
|
Business income
|
|
2000
|
$117,884
|
-$31,112
|
$41,300
|
Business income
|
|
2001
|
$34,554
|
-$57,715
|
$41,439
|
Business income
|
|
2002
|
$14,244
|
-$43,292
|
$44,050
|
Farm income
|
|
2003
|
$18,287
|
-$37,062
|
$43,269
|
Farm income
|
It should be noted that the Appellant
himself described his business income in his income tax returns as farm income,
except for the years from 1999 to 2001;
(c)
For the years 1998 to
2006, the Appellant's gross business income was broken down under the following
heads:
|
|
Woodlot sales
|
Syrup sales
|
Other income
|
Cottage rental
|
Total
|
|
1998
|
20,267
|
14,191
|
2,172
|
|
36,630
|
|
1999
|
215,922
|
14,885
|
3,483
|
|
234,290
|
|
2000
|
77,247
|
26,107
|
14,529
|
|
117,883
|
|
2001
|
14,751
|
15,775
|
4,028
|
|
34,554
|
|
2002
|
36
|
5,345
|
7,480
|
|
12,861
|
|
2003
|
|
3,759
|
13,598
|
|
17,357
|
|
2004
|
1,170
|
5,494
|
5,576
|
2,000
|
14,240
|
|
2005
|
5,949
|
2,000
|
5,322
|
7,600
|
20,871
|
|
2006
|
13,773
|
|
11,578
|
2,400
|
27,751
|
|
______________________________________________________________
|
|
Total
|
349,115
|
87,556
|
67,766
|
12,000
|
516,437
|
(d)
the Appellant's
long-term business debt was $220,851 as at December 31, 2000, $205,514 as at December 31, 2001, $156,408 as at December 31, 2002, $142,276 as at December 31, 2003, $127,040 as at December 31, 2004, $117,242 as at December 31, 2005 and $107,291 as at December 31, 2006;
(e)
the Appellant's capital
contributions to his business were as follows:
|
Year
|
Contribution
|
|
1998
|
‑
|
|
1999
|
12,000
|
|
2000
|
43,387
|
|
2001
|
47,082
|
|
2002
|
39,555
|
|
2003
|
38,070
|
|
2004
|
31,762
|
|
2005
|
18,643
|
|
2006
|
25,301
|
(f)
the interest paid by
the Appellant on the business's long-term debt was as follows:
|
Year
|
Interest paid
|
|
1998
|
2,729
|
|
1999
|
12,960
|
|
2000
|
16,301
|
|
2001
|
16,006
|
|
2002
|
14,548
|
|
2003
|
10,703
|
|
2004
|
7,552
|
|
2005
|
7,011
|
|
2006
|
7,211
|
Appellant's Position
[5]
The position taken by
the Appellant at the hearing is essentially what is set out in his notice of
appeal, which reads as follows:
[TRANSLATION]
I am a lumberjack's son and I was a lumberjack myself by trade from
1969 to 1978. I then took a course in welding and I was hired by Hydro‑Québec
in 1981 and still work for that company.
Since 1983, I have also owned woodlots that today have an
approximate area of 500 acres. The production from cutting these trees is
intended for market: for sawmills, peeling, panels, pulp and paper or firewood.
Because my plan was multi-resource in nature and the geographic
location was favourable to that kind of business, I purchased the land adjacent
to my properties, on which there were already four cottages. After some
maintenance work, the cottages could be rented. As well, the purchase meant
that I could expand my woodlot. To attract customers, we had to be able to
offer activities in all four seasons, and so I rented 146 acres of land from
the Ministère des Ressources naturelles on which there was a maple sugar bush
used to produce maple syrup. The information I had received at the time led me
to believe that the project was viable and profitable. At the same time, the
spring thaw is not a good time for logging, and so I thought I could make that
time of year profitable. Unfortunately, the information I had received from the
consulting Ministère did not turn out to be completely true. But the investment
had been made already. The economic situation in the maple syrup market
collapsed. For all these reasons, my plan was affected and my financial
situation became very precarious. In 2000, my decision to divest myself of my
maple syrup equipment was made, but it was nearly two years before I found a
buyer. What was supposed to be just a sideline to diversify my income became my
economic nightmare.
My business is not a part-time farming business; in fact, it is a
commercial logging business. The income I receive from it comes primarily from
selling timber to plants and paper mills. Since 1988, the year when I set about
diversifying my portfolio, my cumulative gross business income has amounted to
nearly a half-million dollars, and 69% of that income comes from the sale of
timber, according to my financial statements.
I work on cutting down trees and sawing them up. I do not reforest
my land; rather, I prefer to allow natural regrowth, given that there is enough
land to allow for this, and thus contribute to sustainable development. In this
I have the assistance of a forestry engineer, who has in fact drawn up a
management plan for my business. Obviously, however, some work, such as
building roads, has to be done. These hours of work do not generate immediate
income, but expenses. That is why a business has to be looked at in its
entirety. A year when there may seem to be low income does not mean that fewer
hours of work were invested.
I will therefore rely on Interpretation Bulletin IT-373R2 to show
that my woodlot is a commercial woodlot for which there is a management plan
and that I have the skills and experience to operate it. I sell raw materials
for lumber and my income is subject to the market price. I will submit a
document proving the reasonable expectation of profit from my business.
I am convinced, in good faith, that section 31, which restricts the
deductibility of losses, does not apply to my business, because I will show
that my woodlot is commercial and not a farm. Nature alone produces timber, and
I do not carry out any special treatment. I do not "raise" timber. I
harvest timber that grows completely naturally on the land that I own and I
sell it to businesses that process it.
. . .
Analysis
[6]
The Appellant is
essentially arguing that his business (68% of the income from which from 1998 to
2006 came from selling timber) is not a farming business, it is a commercial logging
business. On that point, the Appellant submits that his woodlot has an area of
about 180 hectares and was used for logging activities, while the Respondent
argues that it was used by a farming business.
[7]
I would first like to
quote the following passage from Desrosiers, in which
Dussault J. explained his analysis (which appears to be very much on point in
this case) of the term "farming" as it is defined in subsection 248(1)
of the Act, and the factors that must be considered and that must be analyzed
in the effort to determine whether we are dealing with a farming operation:
51 Subsection 248(1) of the Act does not
provide a true definition of the word "farming". However, it does
indicate the following:
"farming" includes tillage of the soil, livestock raising
or exhibiting, maintaining of horses for racing, raising of poultry, fur
farming, dairy farming, fruit growing and the keeping of bees, but does not
include an office or employment under a person engaged in the business of
farming.
52 Clearly, such a definition is not
intended to be exhaustive. Recourse to the ordinary meaning of the word
therefore seems appropriate in order to determine its scope.
53 In Le Grand Robert, Dictionnaire
alphabétique et analogique de la langue française, 2nd Edition, 1988 (Le
Grand Robert) the primary meaning of the French word
"agriculture" (farming) is given as follows:
Culture,
travail de la terre; par ext., production des plantes et des animaux utiles
fournissant les denrées alimentaires et les matières premières d'autres
industries. --> Culture; apiculture, arboriculture, aviculture,
horticulture, pisciculture, sériciculture, sylviculture, viticulture; élevage;
primaire (secteur primaire).
[TRANSLATION]
Cultivation,
working the land; by ext., production of useful plants and animals providing
foodstuffs and raw materials for other industries. --> Cultivation; bee-keeping,
arboriculture, poultry raising, horticulture, pisciculture, sericulture,
silviculture, viticulture; animal raising; primary (primary sector).
54 While this definition does not set
absolute limits for the scope of the word, it does nevertheless indicate a
number of activities that are associated with it and which go beyond those
already listed in the Act. The words "aboriculture" and
"silviculture" are clearly the ones in which we are interested in the
instant case. There are no definitions of these terms in the Act. Le Grand
Robert defines their French equivalents as follows:
ARBORICULTURE
. . .
Partie
de l'agriculture qui a pour objet la culture des plantes ligneuses. -->
Arbre. Arboriculture forestière. --> Foresterie, sylviculture. - Spécialt.
Production de fruits. Arboriculture fruitière. --> Agrumiculture,
horticulture, pomoculture (ou pomologie), viticulture. Arboriculture
d'ornement. --> Jardinage; horticulture.
[TRANSLATION]
Part
of farming having to do with the cultivation of ligneous plants. --> Tree. Forest
arboriculture. --> Forestry, silviculture. – Esp. Fruit production. Fruit
arboriculture. --> Citriculture, horticulture, --> pome fruit
production(or pomology), viticulture. Ornamental arboriculture. --> Gardening;
horticulture.
SYLVICULTURE
. . .
Didact.
Exploitation rationnelle des arbres forestiers (conservation, entretien,
régénération, reboisement, etc.). --> Arboriculture.
[TRANSLATION]
Tech.
Rational exploitation of forest trees (conservation, maintenance, regeneration,
reforestation, etc.). --> Arboriculture.
55 In the same work, the French verb
"exploiter" (exploit) in the expression "exploiter un bois"
(exploit a woodlot) is given the meaning of "en abattre et débiter les
arbres" (felling and cutting up the trees).
56 Where do these definitions lead us?
While they do not draw an absolute line between the words "farming"
on the one hand and "logging" on the other, they do quite clearly
indicate those activities that are more specifically associated with one or the
other and whose scope it is appropriate to measure, to the extent that farming
and logging are carried on concurrently. In a borderline case like this one,
the solution therefore ultimately hinges on the nature of the activities and their
relative importance.
57 One will have already noted that this
is precisely the approach suggested in paragraph 13 of Interpretation Bulletin
IT-373R2 dealing with woodlots, published on July 16, 1999. As we know, these bulletins
are not binding on the courts but they can prove very useful when
interpretation problems crop up. The recent publication date is not, in my
view, an obstacle as regards this case since the bulletin sets out a logical,
realistic and balanced approach. I would add that, with respect to the question
before us, the ideas expressed in the bulletin are not in any way the result of
recent changes in the legislation or case law. For the sake of convenience, I
cite again paragraph 13 of Interpretation Bulletin IT-373R2, which reads as
follows:
13. Whether a woodlot constitutes a farming operation or a logging
business or another commercial operation is a question of fact. If the main
focus of a business conducted with a reasonable expectation of profit (a
COMMERCIAL WOODLOT) is not lumbering or logging, but is planting, nurturing and
harvesting trees pursuant to a forestry management or other similar resource
plan and significant attention is paid to manage the growth, health, quality
and composition of the stands, it is generally considered a farming business (a
COMMERCIAL FARM WOODLOT). If the main focus of a business is logging (a
commercial non-farm woodlot), and is not growing, nurturing and harvesting
trees, the fact that reforestation activities are carried out would not transform
that business into a farming operation.
[8]
Accordingly, in order
to determine whether the Appellant was operating a farming operation or logging
business, we must establish, in my opinion, based on the evidence submitted,
what activities (in connection with the operation of the woodlots) were really
carried on by the Appellant; we must then determine which of those activities
were associated specifically with one or another of the businesses; and
finally, we must determine their relative importance. In other words, in a
borderline case like this one, the solution must ultimately be determined from
the nature of the activities and their relative importance.
[9]
The activities (in
connection with the operation of the woodlot) that were really carried on by
the Appellant during the years 1987 to 2003 were as follows:
(a)
The Appellant did work
associated with the conservation, maintenance, regeneration and reforestation
of his woodlot (work that, in my opinion, is associated specifically with a
farming operation), on land with an area of a little over nine hectares, that
is, about 5% of the total area of his woodlot, which, it will be recalled,
covered about 180 hectares. I note that starting in 1999 the Appellant did
work of this nature on an area representing barely 2% of the total area of his
woodlot. I would also point out that the Appellant did no work of this nature
during the years in issue.
(b)
The Appellant also
built about 4 kilometres of forest roads on his woodlot, 2.3 kilometres of
which were built during the years in issue. It should be noted that the
Appellant built the forest roads himself, to all intents and purposes, using
the machinery and equipment he owned. In my opinion, that activity must be
associated specifically with the operation of a logging business, and is in no
way associated with a farming operation, because its primary purpose is to
allow the operator to gain access to the forest resource. In fact, forest roads
allow for the rational and profitable exploitation of the forest resource, because
they make it possible for heavy logging equipment to gain access to that
resource and facilitate transportation of the resource to market. On this
point, I would note that Alex Gagnon (the Appellant's forestry engineer for
several years) testified that the forest road construction work was heavy work
and there were few subsidies available for it.
(c)
The last point is that
the Appellant cut and felled trees (work that, in my opinion, is associated
specifically with a logging business) with the wood being destined for sale to
paper mills and sawmills. Although the Appellant could not specify the number
of hectares on which the logging work was done starting in 1987, the evidence
did show that during the years from 1998 to 2006, the Appellant's business
generated cumulative gross income of about $500,000, 68% of which came from the
sale of timber to sawmills and paper mills. In fact, the Appellant's annual
sales during that period totalled about $39,000, on average. It should be noted
that the logging work was done by the Appellant during that period, with the
exception of 1999 and 2000, when he hired subcontractors to do it. I would also
note that the Appellant did not do logging during the years in issue.
[10]
Counsel for the
Respondent argued that the primary focus of the Appellant's business was not
"lumbering or logging, but [was] planting, nurturing and harvesting trees
pursuant to a forestry management or other similar resource plan", to
quote paragraph 13 of Interpretation Bulletin IT‑373R2, essentially because
the Appellant has not shown that the logging was done on areas larger than the
areas where the work associated with conservation, maintenance, regeneration
and reforestation was done, that work, I would point out, having been done on
an area representing barely 5% of the total area of the Appellant's woodlot.
Counsel for the Respondent also stressed that the Appellant described his
business as a farming operation in his income tax returns.
[11]
It seems to me to be
reductionist and simplistic, at the least, to decide that the Appellant's
business is a farming operation on the ground that he has failed to show that
the logging was done on an area larger than the area where the work associated
with conservation, maintenance, regeneration and reforestation was done. The
factor involving the area associated with either of the activities is a factor
that must be considered, but in my opinion it cannot be decisive, particularly
when, in this case, the so-called farming work has been done, since 1987, on
barely 5% of the area of the woodlot, and barely 2% of the area since 1999.
Rather, we must consider a series of factors, in particular the time and
financial or other resources devoted to each of the activities by the
Appellant. On that point, it seems to me to be implausible to conclude, having
regard to the evidence submitted, that the time spent by the Appellant on
logging and building forest roads from 1987 to 2003 was less significant than
the time spent maintaining, conserving, regenerating and reforesting on less
than 5% of the area of the woodlot. It also seems obvious to me that the
largest share of the financial resources was devoted by the Appellant to
building forest roads and cutting timber.
[12]
For these reasons, it
is my opinion that the Appellant's business was not a farming operation, it was
a logging business, because the activities associated strictly with the logging
business were more significant than the activities associated specifically with
a farming operation. Accordingly, the Appellant was entitled to deduct the
losses associated with the operation of the logging business during the years
in issue from his income from employment in the same years.
[13]
For these reasons, the
appeal is allowed.
Signed at Ottawa, Canada, this 20th day of May, 2008.
"Paul Bédard"
Translation
certified true
on this 3rd day of
July 2008.
Brian McCordick,
Translator
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