The double-dip structures and the tower structures that you are referring to are culminated in the rules dealing with foreign affiliates, which have nothing to do with this bill. Under a tower structure or a double-dip structure, basically, interest paid by one foreign affiliate to another--a foreign affiliate of a taxpayer--is treated as being active business earnings. The reason for that is that the interest expense paid reduces the active business earnings of one foreign affiliate, so we increase the active business earnings of the other foreign affiliate to keep the affiliates' group active business earnings flat, at the same amount. That's the reason for the provision.
The effect of that provision is being used by Canadian corporate groups to essentially move income out of a high-tax jurisdiction into a low-tax jurisdiction. That really doesn't affect the Canadian treasury; that affects foreign treasuries. From that point of view, it's not offensive from a Canadian tax policy point of view.