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Gary Berchowitz

Sep 29, 2026

9:06
So could you give a little bit of thoughts into how that affected the discussion?
9:10
Yeah, and I think at least for me personally, this is the thing I struggled with most in the question, because as I mentioned, the submission was written in the context of an investment fund and how it might do this 53C assessment.
9:23
And I think many committee members are really struggling with that as the question, because intuitively, a lot of the committee was saying, but if I was an investment fund funder, I would start by saying, surely it's my main business activity to invest in equity and debt instruments or assets.
9:42
And so why would I come to the 53C assessment if it's obvious without a huge amount of analysis that I have investing in this particular type of asset as a specified main business activity, in which case, it's there anyway.
9:59
So I think that was a real challenge for a lot of the committee members.
10:03
But I think because the submission didn't focus on determining the specified main business activity of this entity, it wanted the assessment to be done just on the individual and large independent, people kind of had to suspend their disbelief for a second and say, okay, let's assume you've gone through the assessment and you've considered whether or not you have specified main business activities, but now we're asking the question of 53C.
10:27
So I do think, and I think it comes through in the TAD, Folks shouldn't forget that you need to consider whether or not you have a specified main business activity at the same time before as part of doing this 53 assessment.

13 MINS LATER

23:19
So where did the committee get to in the

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