Finance committee  We're certainly aware. I have one particular example on the go in which if a taxpayer transfers a particular asset on which there is an advanced income tax ruling based on an outstanding comfort letter and included in Bill C-48, the accounting treatment is very odd. It would give rise to recording all of the tax in the financial statements.

Finance committee  It's a very big bill and I think it's been studied a lot by a lot of people. As Mr. Shillinger mentioned previously, the Department of Finance has been open to consultation on a number of the provisions in the bill. At this time it does make sense to get on and pass the bill, and if there are further technical amendments required, they should be made after the fact, at a later date.

Finance committee  That's a very difficult question, in a sense. I think it is fair to say that businesses and corporations, and individuals for that matter, plan their affairs based on actual tax legislation. It's very clear that this legislation is aimed at fairness, that it does close a number of loopholes, and that it does broaden the base in certain circumstances.

Finance committee  Absolutely, and it's not just our job; it's getting on with business for our clients.

Finance committee  I think that taxpayers do very much rely on both draft legislation and comfort letters. Most of the changes that we're talking about here are very technical in nature. They don't seem to typically deal with policy. We've lived with the system. Some of the amendments in this bill go back to as far as 1996, and taxpayers, while they regret having to follow so many versions of draft legislation, do try to do that.

Finance committee  I would just say try to get on with it and push the process through Parliament. It seems that most of the bills have died on the order paper and could have been pushed through. We wouldn't be sitting here today with quite so much. This is quite a bit.

Finance committee  Thank you, and good morning. My name is Greg Boehmer. I'm a tax partner with Ernst & Young, and on behalf of the firm, I'd like to thank you for the opportunity to appear before this committee in connection with Bill C-48. It's important in our role as tax advisers with clients that we be able to provide our advice to our clients based on legislation that is both clear and certain.