Charles,
To help assist you in properly handling your future win at the World Series of Poker, I have created the following document for you:

CANADA

June 1, 2006

Mr. Charles Allen
R-6991

Mr. Allen,

As a courtesy to you and on behalf of our fine organization I provide you with the following information:

I have reviewed the current “Income Tax Treaty” existing between the Government of the United States of America and the Government of Canada.

My review of the Treaty, signed September 26, 1980 and ratified August 16, 1984 with its attached protocols signed respectively June 14, 1983, March 28, 1984, March 17, 1995 and July 29, 1997, comprises but is not limited to the following:

1) Reviewing the complete Treaty.

2) Determining whether poker gaming winnings received by a nonresident Canadian citizen while in the United States, is subject to the thirty percent (30%) withholding provisions of the U.S. Internal Revenue Code and its applicable regulations.

Based upon my review, it appears a nonresident Canadian citizen is subject to the withholding provisions of the Internal Revenue Code and its applicable regulations for poker tournament winnings.

The protocol entered into on March 17, 1995, specifically Article 11, provides that a Canadian citizen who experiences a poker tournament gaming win within the United States which is subject to the 30% withholding provisions of the U.S Internal Revenue Code and its applicable regulations may petition the United States Government for a refund of the withheld monies. To initiate the refund, the Canadian citizen must file Internal Revenue Service Form 1042-S and provide proper documentation/substantiation for gaming losses claimed that offset the reported poker gaming win.

Respectfully submitted,

James L. Perlowski, CPA