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Donald Howden's Submission in Response to Finance Canada's Tax and Other Issues Related to Publicly Listed Flow-Through Entities (Income Trusts and Limited Partnerships) consultation:

Donald Howden
The Howden Rowein Group
of Raymond James Ltd.
2300 10060 Jasper Ave.
Edmonton AB
T5J 3R8

Dear Sir,

I am the head of a five person team whose responsibility is to advise clients, the large majority of whom are retired, on matters pertaining to their investment portfolios. I am now in my 30th year of such practice.

I can well appreciate the government's concern about the extent of growth within the income trust sector in recent years. Admittedly some of this growth has been only motivated by companies wishing to lessen their tax burden as well as investment bankers who wish to earn rich fees from such conversions.

My concern, however, is for the many Canadians who wish to use their savings and investments as an important tool in their retirement. Contrary to what some may believe, the vast majority of these investors are hard working Canadians. Their contribution to our country is without peer. They are neither rich nor privileged. They have no desire to "cheat" on their income tax but they do desire to take advantage of tax laws that were put in place to both assist industry as well as investors.

Today, the income trust sector is one of the few places a senior Canadian, of at least modest means, can find in order to supplement their income in a reasonably tax efficient manner. This sector is not without risk. However, within a free and open market investors accept this risk knowing that the resulting returns have a reasonable chance of being at least fair.

I urge you to not make meaningful changes to the tax structure of this sector. Otherwise, the political fallout will be considerable and many, many Canadians will be poorer for it.

Don Howden

The Howden Rowein Group
Edmonton, Alberta