Income tax: Hillston Grove Vineyards Project

the Project used unfunded bridging finance for a significant number of investors, not disclosed in the application for the Product Ruling; 2. the services performed by the parties to the Project were not in accordance with those described in the arrangement; 3. consideration for entering a number of management agreements was not in accordance with that described in the arrangement; and 4. some investors have been forgiven amounts in a manner not disclosed in the application for the Product Ruling.